Guo Wengui / Miles Guo — bankruptcy case · ECF #3700

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

-------------------------------------------------------- x SIXTH INTERIM FEE APPLICATION COVER SHEET

Interim Application of: Paul Hastings LLP

Bankruptcy Petition Filed: February 15, 2022 (main chapter 11 case) Date of Entry of Retention Orders: August 2, 2022 [Docket No. 668] (effective as of July 8, 2022, as to Individual Debtor) and January 24, 2023 [Docket No. 1376] (effective as of October 11, 2022, as to Genever (BVI) and effective as of November 3, 2022, as to Genever (US))

Fees: \$5,053,513.53 Voluntary Fee Reductions: \$251,492.22 Expenses: \$165,738.27 Voluntary Expense Reductions: \$0.00

Fees Previously Requested: Retainer Request:

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 This Application does not include any fees and expenses related to the month of August 2024. Paul Hastings will include such fees and expenses in its next interim fee application.

3 In accordance with the Interim Compensation Procedures Order (as defined below), Paul Hastings received payments in the amount of \$937,263.85 in fees and \$1,089,390.98 in expenses with respect to its monthly fee statements for April and May 2024, respectively. Paul Hastings has not yet received payment of its fees and expenses with respect to its monthly fee statements for June and July 2024 (but 80% of such fees and all such expenses may be paid, at a future date, in accordance with the Interim Compensation Procedures Order). In addition, while this Application seeks allowance of all fees incurred during the Fee Period (other than with respect to the civil RICO action), Paul Hastings is not seeking, at this time, payment of the 20% holdback with respect to the April through July 2024 fee statements.

Expenses Previously Requested: Expense Detail:

Requested Expenses: \$1,753,367.83 Retainer Received: N/A Awarded Expenses: \$1,746,426.61 Copies per page cost and total: \$0.08 b/w Paid Expenses: \$1,746,426.61 (per page)

Expenses Fees Awarded and Paid;

Expense Reimbursement Application for the Period from July 8, 2022 through October 31, 20224

Docket No.

10/31/22 \$0.00 \$63,631.75 Not applicable Awarded: \$63,631.75 Paid:

Special Fee Application (Sanctions) for Services Rendered in Securing Compliance with Court-Authorized Subpoenas5

Docket No.

3/10/23 \$83,370.26 Awarded: \$83,370.26 Paid:

First Interim Fee Application for the Period from July 8, 2022 through February 28, 2023

Docket No.

2/28/23 \$12,326,802.00 \$348,813.54 Awarded: \$11,776,802.00 Paid:

on 6/29/23 \$11,776,802.00 Awarded: \$348,813.54 Paid:

Second Interim Fee Application for the Period from March 1, 2023 through June 30, 2023

Docket No.

credit)6 \$213,914.83 Awarded: \$7,982,720.00 Paid:

on 9/12/23 \$6,386,176.00 Awarded: \$213,914.83 Paid:

Docket No.

8/31/23 Third Interim Fee Application for the Period from July 1, 2023 through August 31, 2023 \$3,725,984.25 \$146,137.57 Awarded: \$3,525,984.25 Paid:

on 11/30/23 \$2,820,787.407 Awarded: \$146,137.57 Paid:

4 The First Interim Fee Application excluded the expense reimbursements requested in the Expense Reimbursement Application.

- 5 The First Interim Fee Application and the Second Interim Fee Application included the amounts sought in the Special Fee Application (for the period through February 28, 2023 and the period from March 1 - 10, 2023, respectively). Paul Hastings included these amounts not to recover twice but to ensure payment in the event the HK Parties (defined below) do not comply with the Sanctions Order (defined below). In July 2024, the Trustee received payment in the amount of \$83,370.26 from one of the HK Parties. Given that the Trustee was able to recover these fees from one of the HK Parties, Paul Hastings is not seeking further payment of such fees from the estates. - 6 Due to an inadvertent oversight, the monthly fee statements for January and February 2023 (which were covered in the First Interim Fee Application) did not reflect the voluntary reduction in the hourly rate of the Trustee (from \$1,975 to \$1,860 per hour), resulting in an overstatement of Paul Hastings' fees by \$20,096.25 with respect to these two months. This amount was credited in the Second Interim Fee Application against fees requested therein. - 7 Pursuant to the order granting the Third Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$2,820,787.40. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of July and August 2023 was \$2,980,787.40. The overpayment of \$160,000.00 (i.e., 80% of \$200,000.00) was credited on Paul Hastings' September fee statement.

Date Period Requested Fees Requested Fees Awarded and Paid; Expenses Awarded and Amount

Submitted / Covered Expenses Court Order Paid; Court Order Owing Docket No. Fourth Interim Fee Application for the Period from September 1, 2023 through December 31, 2023 2/19/24 9/1/23 - \$6,911,034.50 \$718,236.31 Awarded: \$6,718,104.50 Awarded: \$714,717.61 \$1,343,620.90

Paid: Paid:

2935 Docket No. 3031, entered Docket No. 3031, entered

Fifth Interim Fee Application for the Period from January 1, 2024 through March 31, 2024 6/24/24 1/1/24 - \$4,141,700.76 \$262,633.83 Awarded: \$4,037,000.70 Awarded: \$259,211.31 \$807,400.14

Paid: 3283 Docket No. 3357, entered Docket No. 3357, entered

Total Awarded: \$34,040,611.45 Awarded: \$1,746,426.61 \$4,452,761.89 Paid: \$29,587,849.56 Paid:

8 Pursuant to the order granting the Fourth Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$5,374,483.60, of which \$160,000.00 was applied as a credit pursuant to the order granting the Third Interim Fee Application.

9 Pursuant to the order granting the Fifth Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$3,229.600.56 in fees. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of January, February, and March 2024 was \$3,333,307.41. The overpayment of \$103,706.85 was credited on Paul Hastings' April 2024 fee statement.

10 Pursuant to the order granting the Fifth Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$259,211.31 in fees. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of January, February, and March 2024 was 262,633.83. The overpayment of \$3,422.52 was credited on Paul Hastings' April 2024 fee statement.

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11 On August 18, 2023, the Court entered the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals [Docket No. 2094] (the "Interim Compensation Procedures Order"), pursuant to which estate professionals (including Paul Hastings) commenced filing monthly fee statements.

12 Reflects \$103,706.85 credit pursuant to the order granting the Fifth Interim Fee Application.

13 Reflects \$3,422.52 credit pursuant to the order granting the Fifth Interim Fee Application.

14 As detailed below, as a further accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of six (6) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$14,116.00; however, such fees were included in the fee statements for the Fee Period. If this Application is granted, Paul Hastings will credit such amount on its subsequent monthly fee statement. HOURS AND RATES PER PROFESSIONAL AND PARAPROFESSIONAL DURING FEE PERIOD15

Axelrod, Peter, Litigation, 1997 \$1,775.00 6.90 \$12,247.50 N/A Bassett, Nicholas Corporate, 2007 \$1,835.00 427.30 \$784,095.50 3 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$917.50 6.00 \$5,505.00 3 Despins, Luc Restructuring, 1986 \$1,975.00 281.40 \$555,765.00 1 Despins, Luc (travel; ½ rate) Restructuring, 1986 \$987.50 4.30 \$4,246.25 1

Bongartz, Alex Restructuring, 2007 \$1,850.00 274.90 \$508,565.00 3 Bongartz, Alex (travel, ½ rate) Restructuring, 2007 \$925.00 4.80 \$4,440.00 3 Maza, Shlomo16 Corporate, 2012 \$1,850.00 74.10 \$137,085.00 3 Traxler, Katherine Restructuring, 1990 \$1,120.00 8.30 \$9,296.00 3

Barron, Douglass Corporate, 2012 \$1,395.00 546.60 \$762,507.00 3

½ rate) Corporate, 2012 \$697.50 0.80 \$558.00 3 Catalano, Kristin Corporate, 2021 \$1,185.00 102.90 \$121,936.50 3

½ rate) Corporate, 2021 \$592.50 10.60 \$6,280.50 3 Daly, Crispin Restructuring, 2010 \$1,395.00 37.70 \$52,591.50 3 Farmer, Will Corporate, 2018 \$1,390.00 80.00 \$111,200.00 3 Kim, Sarah Litigation, 2023 \$985.00 157.70 \$155,334.50 N/A Kosciewicz, Jon Litigation, 2021 \$1,185.00 292.80 \$346,968.00 3 Maza, Shlomo16 Corporate, 2012 \$1,395.00 74.20 \$103,509.00 3 Sadler, Tess Corporate, 2019 \$1,365.00 25.50 \$34,807.50 3 Selva, Gianmarco Corporate \$565.00 33.50 \$18,927.50 N/A Song, Luyi Corporate, 2023 \$985.00 642.30 \$632,665.50 3 Song, Luyi (travel; ½ rate) Corporate, 2023 \$492.50 31.60 \$15,563.00 3 Sutton, Ezra Corporate, 2021 \$1,270.00 474.70 \$602,869.00 3 Sylvia, Daniel Corporate, 2021 \$1,270.00 5.30 \$6,731.00 N/A Yu, Annie Corporate, 2024 \$885.00 8.50 \$7,522.50 N/A Associate Total: 2,524.70 \$2,979,971.00

Doherty, Allison Paralegal \$445.00 15.60 \$6,942.00 N/A Kuo, Jocelyn Paralegal \$565.00 32.10 \$18,136.50 1 Laskowski, Mat Paralegal \$565.00 14.40 \$8,136.00 2

15 Reflects reduction of \$14,116.00 for fees of six (6) timekeepers who billed less than five (5) hours during the Fee Period.

16 Shlomo Maza was promoted to Of Counsel effective July 1, 2024.

Mohamed, David Paralegal \$565.00 315.10 \$178,031.50 2 Vitti, Johnna Paralegal \$485.00 6.80 \$3,298.00 N/A Paraprofessional Total: 394.10 \$218,786.00

Voluntary fee reduction related to document review: (\$166,488.72)

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

-------------------------------------------------------- x SIXTH INTERIM FEE APPLICATION OF PAUL HASTINGS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM APRIL 1, 2024 THROUGH JULY 31, 2024

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (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 [Docket No. 2094] (the "Interim Compensation Procedures Order"), Paul Hastings LLP ("Paul Hastings"), as counsel to (a) Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Individual Debtor"), (b) Genever Holdings Corporation ("Genever (BVI)"), and (c) Genever Holdings LLC ("Genever (US)" and, together with Genever (BVI), the "Genever Debtors"), hereby files this

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).

*Sixth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from April 1, 2024 through July 31, 2024* (the "Application"). By this Application, Paul Hastings requests allowance and payment2 of the compensation for professional services performed by Paul Hastings attorneys (including the Trustee3 ) and reimbursement of its actual and necessary expenses incurred during the period from April 1, 2024 through and including July 31, 2024 (the "Fee Period"). In support of this Application, Paul Hastings respectfully states as follows:

1. During the Fee Period, the Trustee and Paul Hastings continued the investigation into the financial affairs of the Individual Debtor and his corporate "shell game" to shield companies and assets under his ownership and/or control from his creditors. Given the vast network of companies affiliated with the Individual Debtor, and the fact that these companies or their assets are located around the world, the Trustee's investigation was, and continues to be, extensive. As the Court is also aware, during the Fee Period, the Trustee also continued to prosecute, with the assistance of Paul Hastings and the Trustee's other advisors, numerous adversary proceedings asserting alter ego and equitable ownership claims (or similar claims

2 In accordance with the Interim Compensation Procedures Order (as defined below), Paul Hastings received payments in the amount of \$937,263.85 in fees and \$1,089,390.98 in expenses with respect to its monthly fee statements for April and May 2024, respectively. Paul Hastings has not yet received payment of its fees and expenses with respect to its monthly fee statements for June and July 2024 (but 80% of such fees and all such expenses may be paid, at a future date, in accordance with the Interim Compensation Procedures Order). In addition, while this Application seeks allowance of all fees incurred during the Fee Period (other than with respect to the civil RICO action), Paul Hastings is not seeking, at this time, payment of the 20% holdback with respect to the April through July 2024 fee statements.

3 In accordance with the Retention Order (as defined below), the Trustee is authorized to act as one of the attorneys for the Individual Debtor's estate, and, accordingly, this Application also seeks allowance of the Trustee's fees in such capacity. For the avoidance of doubt, in this Application, references to services provided by Paul Hastings attorneys shall include the Trustee. To be clear, time spent by the Trustee in his capacity as chapter 11 trustee, is not part of this Application, and compensation therefor will be sought by separate application. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 10 of 700

under applicable law) as well as approximately 300 adversary proceedings seeking to avoid

fraudulent transfers and postpetition transfers (the "Avoidance Actions").

2. As part of the Trustee's efforts to recover assets for the benefit of the estates, the

Trustee continued to make substantial progress, including in several pending adversary

proceedings and appeals. For example:

- HCHK Adversary Proceeding: During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against HCHK Technologies, Inc. ("HCHK Technologies"), HCHK Property Management, Inc. ("HCHK Property"), Lexington Property and Staffing, Inc. ("Lexington Property," and, together with HCHK Technologies and HCHK Property, the "HCHK Entities"), Brian Hofmeister, in his capacity as assignee of the HCHK Entities (the "Assignee"), and certain other parties, seeking determinations that, among other things, (a) the HCHK Entities are alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets. - o Following this Court's denial of certain defendants' motion to set aside the entry of default as against them, Paul Hastings attorneys prepared the Trustee's motion for default judgment against the HCHK Entities and the other defendants. - o On June 14, 2024, the Court granted the Trustee's motion for default judgment, holding, among other things, that the HCHK Entities are the alter egos of the Individual Debtor and directing that the property of the HCHK Entities be turned over to the estate.As a result of this ruling, among other things, over more than \$38 million of the HCHK Entities' funds (previously transferred into accounts controlled by the Trustee pursuant to the settlement with the Assignee) are now property of the estate. - o Omnibus Alter Ego Adversary Proceeding: During the Fee Period, Paul attorneys continued to pursue the Trustee's adversary proceeding against various entities, including K Legacy Ltd. ("K Legacy"), seeking declarations that such entities are alter egos of the Individual Debtor and/or their assets are beneficially owned by the Individual Debtor, such that their assets are property of the estate. - o While this adversary proceeding was temporarily stayed (other than with respect to K Legacy) pending the conclusion of the Individual Debtor's Criminal Trial (as defined below), following the guilty verdict and conclusion of the Individual Debtor's Criminal Trial on July 16, 2024, this adversary proceeding resumed.

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- o On September 12, 2024, the Trustee obtained entries of default as against K Legacy and the Debtor's son, i.e., Qiang Guo, pursuant to which the Court held, among other things, that the ownership interests in K Legacy and the assets of K Legacy, including a luxury apartment in London, are property of the estate. - o In addition to the default judgment against K Legacy and the Debtor's son, the Trustee has also recently commenced proceedings in the British Virgin Islands ("BVI"), i.e., the jurisdiction where K Legacy is incorporated, to, among other things, rectify K Legacy's membership list and establish the estate's ownership of K Legacy and the London apartment. - Mei Guo Adversary Proceeding: During the Fee Period, Paul Hastings continued, in conjunction with the Trustee's local Connecticut counsel, Neubert Pepe & Monteith, P.C. ("NPM"), to prosecute the Trustee's adversary proceeding against Mei Guo. In this adversary proceeding, the Trustee seeks determinations that, among other things, (a) more than \$10 million in proceeds from the sale of the Individual Debtor's private Bombardier jet are property of the estate and (b) a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate. - o On April 3, 2024, the Court granted, in part, the Trustee's motion for summary judgment, holding, among other things, that the Individual Debtor beneficially owned the Bombardier jet and, hence, beneficially owns the Bombardier proceeds, and directing Mei Guo to turn over to the estate the Bombardier proceeds. Following the Court's decision, more than \$10 million in Bombardier proceeds were turned over to the estate. - Greenwich Land Adversary Proceeding: During the Fee Period, Paul Hastings continued to prosecute the Trustee's adversary proceeding against Greenwich Land LLC ("Greenwich Land") and the Individual Debtor's alleged wife (i.e., Hing Chi Ngok), seeking determinations that, among other things, (a) Greenwich Land (which holds legal title to the Individual Debtor's residence in Greenwich, Connecticut) is an alter ego of the Debtor and (b) the Debtor is the equitable owner of Greenwich Land. - o On July 3, 2024, the Court granted the Trustee's motion for summary judgment, holding, among other things, that Greenwich Land is an alter ego of the Individual Debtor and directing that the property of Greenwich Land be turned over to the estate. As a result of this ruling, among other things, the multi-million-dollar mansion located at 373 Taconic Road, Greenwich, Connecticut (the "Taconic Property") is now property of the estate. - o On September 30, 2024, the Trustee filed a motion to sell the Taconic Property for a purchase price of \$6.9 million. The Trustee subsequently filed a notice to the Court on October 14, 2024 regarding a higher and better offer to purchase the Taconic Property for \$7.25 million. The hearing on the sale motion is scheduled for October 15, 2024. - VCTR Shares: Through his investigation of the Individual Debtor's financial affairs, the Trustee learned that Lamp Capital—which the Court found to be an alter ego of the Individual Debtor—owns a limited partnership interest in the Reverence Capital Partners Opportunities Fund I (Cayman) L.P. (the "Reverence Fund"). The interest—which is property of the estate—includes rights to receive distributions from the publicly traded VCTR Shares and unpaid cash distributions. - o On June 12, 2024, the Court granted the Trustee's motion, holding, among other things, that the limited partnership interest is property of the estate, and approving the liquidation of the VCTR Shares and distribution of net proceeds to the Trustee for the benefit of the estate. - o On August 6, 2024, the Trustee filed a report noting that on July 31, 2024, he received for the benefit of the estate a distribution from Reverence Fund in the amount of more than \$2.7 million. - Ducati Motorcycle: Through his investigation of the Individual Debtor's financial affairs, the Trustee identified a Ducati Diavel motorcycle which was parked in the Mahwah Mansion and whose registered owner is Mr. Scott Barnett. - o On May 28, 2024, the Court granted the Trustee's motion, holding, among other things, that the Ducati motorcycle is property of the estate. - Defeng Cao Adversary Proceeding: During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint seeking determinations that six separate vehicles—three Harley Davidsons and one BMW motorcycle, as well as one Land Rover Defender and one Dodge Ram Pickup Truck—which, while nominally held by the defendant, were fraudulently transferred to Defeng Cao (Mei Guo's long-term boyfriend), or alternatively, are equitably owned by the Individual Debtor. - o During the Fee Period, the Trustee filed his motion for judgment on the pleadings with respect to the four luxury motorcycles and reply in support of this motion. - o On September 9, 2024, the Court granted the Trustee's motion for judgment on the pleadings, holding that the motorcycles are property of the estate and requiring Mr. Cao to turn them over to the estate. - Ace Decade Adversary Proceeding: During the Fee Period, Paul Hastings continued to handle the Trustee's adversary proceeding against Ace Decade Holdings Limited ("Ace Decade"), Yvette Wang, and Rui Hao seeking a declaration that the transfer of the Ace Decade share by Yvette Wang to Rui Hao is void, in light of this Court's prior ruling that the Trustee beneficially owns the Ace Decade shares. - o During the Fee Period, the Court granted the Trustee's motion for entry of default judgment as against Yvette Wang and Ace Decade. On September 12, 2024, the Court also entered a default judgment against Rui Hao. - o In addition, the Trustee must also seek relief in the BVI to rectify the membership list for Ace Decade to reflect the estate's ownership of Ace Decade. These matters are further complicated by the commencement of liquidation proceedings with respect to Ace Decade (and the appointment of joint liquidators) in the BVI. Paul Hastings is working with the Trustee's BVI counsel to evaluate next steps in this regard. - Mahwah Adversary Proceeding: During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC ("Taurus Fund"), and Taurus Management LLC—until such action was stayed at the request of the Trustee. In this adversary proceeding, the Trustee seeks determinations that, among other things, (a) the Individual Debtor is the equitable owner of a 50,000 square foot, castle-styled private residence with 12.5-acre grounds located at 675 Ramapo Valley Road, Mahwah, New Jersey 07430 (the "Mahwah Mansion"), (b) the Debtor is the equitable owner of Taurus Fund (the entity holding title to the Mahwah Mansion), and (c) that Taurus Fund is an alter ego of the Individual Debtor. - o During the Fee Period, Paul Hastings attorneys coordinated with NPM to address the fact that Taurus Fund ceased to pay security and other maintenance expenses for the Mahwah Mansion following the guilty verdict and conclusion of the Individual Debtor's Criminal Trial. Among other things, the Trustee obtained Court authorization to fund these security and maintenance costs. - Appeals: The Trustee also made significant progress in the various appeals of order of this Court. For example: - o On August 23, 2024 (i.e., after the conclusion of the Fee Period), the United States District Court for the District of Connecticut (the "District Court") affirmed this Court's orders granting the Trustee's motion for summary judgment in which this Court determined that the Individual Debtor was the beneficial owner of the Lady May yacht and that HK International Funds Investment (USA) Limited, LLC ("HK USA") was the

Individual Debtor's alter ego. Clerk of the District Court entered judgment in favor of the Trustee on September 5, 2024.

- o Paul Hastings attorneys spent significant time briefing the proposed intervenors' appeal of this Court's order denying their motion to intervene in the HCHK Adversary Proceeding. On August 29, 2024, after briefing concluded, the proposed intervenors filed a stipulation dismissing the appeal with prejudice. - o Paul Hastings attorneys also spent significant time briefing the HCHK entities' related appeal of this Court's order granting default judgment against such entities. After briefing concluded, the HCHK entities' counsel withdrew its appearance in the appeal. - o On September 30, 2024, the District Court affirmed this Court's preliminary injunction order against the Individual Debtor and those within his control prohibiting the intimidation and harassment of the Trustee and PAX during the protest activities. - Motions to Withdraw References: Paul Hastings attorneys also continued to work on responses to several defendants' motions to withdraw the reference. For example: - o On August 30, 2024, the Trustee filed his objection to the motion to withdraw the reference of the Mahwah Adversary Proceeding filed by Taurus Fund, Taurus Management LLC, and Scott Barnett.

3. Moreover, during the Fee Period, the Trustee and his professionals continued to

prosecute approximately 300 Avoidance Actions and handled issues including (a) analyzing potential avoidance claims, (b) preparing and filing additional Avoidance Action complaints and the Trustee's responses to Avoidance Action defendants' motions to dismiss, (c) preparing the Trustee's motion for judgment on the pleadings, (d) meeting and conferring with counsel for Avoidance Action defendants, (e) developing strategies for potential settlements, and (f) handling hearings and status conferences in such Avoidance Actions. In addition, the Trustee and his professionals also prepared for and conducted mediation presentations in June and July, 2024, including an introductory presentation addressing various groups of mediation parties, and Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 15 of 700

conferred with the mediator, i.e., U.S. Bankruptcy Judge James J. Tancredi, the mediator, about the mediation processes.

4. Given the enormity of the Trustee's task and the continued obstruction by the Debtors' associates and alter ego companies, coupled with the delay in Trustee's investigation caused by the Individual Debtor's Criminal Trial, it was impossible for the Trustee to complete his investigation and assert all available causes of action prior to August 15, 2024 (i.e., the extended deadline granted by the Court on February 15, 2024). For that reason, Paul Hastings, in conjunction with NPM, prepared the Trustee's motion to extend the August 15, 2024 deadline for the Trustee to commence actions to avoid and recover fraudulent transfers and/or assert other estate causes of action (which motion was filed on July 19, 2024). The Court granted this motion by order dated August 14, 2024.

5. In addition, as part of the Trustee's investigation, the Trustee continued to monitor the criminal case (the "Criminal Case") pending against the Individual Debtor in the United States District Court for the Southern District of New York [Case No. 1:23-cr-00118-AT] (the "SDNY Court"). In particular:

- On May 3, 2024, the Individual Debtor's co-defendant and chief of staff Yvette Wang pleaded guilty to one count of conspiracy to commit wire fraud and one count of conspiracy to commit money laundering. The statutory maximum term of imprisonment on the two counts is ten years. Yvette Wang's sentencing hearing is currently scheduled for October 21, 2024. - The trial in the Individual Debtor's Criminal Case (the "Criminal Trial") commenced on May 22, 2024. During the eight-week trial, the jury heard testimony from 34 government witnesses and nine defense witnesses. On July 16, 2024, a unanimous jury found the Debtor guilty on nine of the 12 charges, including racketeering conspiracy, conspiracy to commit wire fraud and bank fraud, money laundering conspiracy, conspiracy to commit securities fraud, and multiple wire fraud and securities fraud charges. The Individual Debtor's sentencing hearing is currently scheduled for December 2024.

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 16 of 700

- The Criminal Trial also made public thousands of government exhibits, which contain important information that the Trustee had not learned in discovery and supplemented the Trustee's ongoing investigation efforts. - During the Fee Period, Paul Hastings attorneys continued to analyze various legal issues related to the criminal forfeiture allegations of over \$630 million in assets seized by the U.S. government in the Individual Debtor's Criminal Case.

6. Furthermore, during the Fee Period, the damage caused by the fire on March 15, 2023 at the 18th floor apartment at the Sherry Netherland (the "Sherry Netherland Apartment") continued to require the Trustee's and Paul Hastings' attention. Among other things, Paul Hastings attorneys worked with Genever (US)'s architect (Acheson Doyle) and other service providers to conduct the remediation and cleaning of the Sherry Netherland Apartment, including remediation of soot and other combustion by-products and ancillary services such as abating asbestos in the affected area, moving furniture into storage, and disposing certain items of inconsequential value. The remediation and cleaning projects are substantially completed, such that, beginning in September 2024, the Trustee began marketing the Sherry Netherland Apartment.

7. All the while, during the Fee Period, the Trustee and Paul Hastings provided a wide range of other chapter 11 related services, including, for example, handling ten hearings and status conferences, preparing and prosecuting numerous substantive motions, and preparing monthly operating reports.

8. As detailed in this Application, Paul Hastings has performed all of its services in an economic, effective, and efficient manner commensurate with the complexity and importance of the issues involved. The work performed by Paul Hastings was carefully assigned to appropriate professionals or paraprofessionals according to the experience and level of expertise required for each particular task. Whenever possible, Paul Hastings sought to minimize the costs Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 17 of 700

of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. Moreover, as detailed below, Paul Hastings has delegated numerous work streams (including the recent avoidance actions process) to local Connecticut counsel (which has a lower rate structure than Paul Hastings).

9. To further minimize the costs of intra-Paul Hastings communications and education about these chapter 11 cases, the Trustee utilized a small group of Paul Hastings attorneys for the majority of the work in these chapter 11 cases. Also, as a general matter, in addition to the Trustee, no more than two Paul Hastings attorneys attended the various hearings held during the Fee Period (and in some instances, the Trustee handled hearings without attendance of any Paul Hastings attorneys), thereby minimizing not only the time billed on these hearings/sessions but also the cost of travel. Furthermore, to the extent appropriate, the Trustee and Paul Hastings sought to work closely with counsel to Pacific Alliance Asia Opportunity Fund L.P. ("PAX"), including to take advantage of the knowledge of the Individual Debtor's assets and financial affairs that PAX acquired during the prepetition litigation against the Individual Debtor in New York state court. Moreover, as noted on the record at the August 2, 2022 hearing on Paul Hastings' retention application, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

10. In addition, Paul Hastings has also voluntarily waived a total of \$166,488.72 in fees incurred during the Fee Period related to the review of documents.

11. Finally, as an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of six (6) timekeepers who billed less than five (5) hours during the Fee Period Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 18 of 700

in the aggregate amount of \$14,116.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

12. In sum, Paul Hastings respectfully submits that the services for which it seeks compensation in this Application were necessary for and beneficial to these chapter 11 estates and their stakeholders. Accordingly, in light of the nature and complexity of these chapter 11 cases, Paul Hastings' charges for professional services performed and expenses incurred are reasonable under applicable standards. For all these reasons, Paul Hastings respectfully requests that the Court grant the Application and allow interim compensation for professional services performed and reimbursement for expenses as requested. JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

13. 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.

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

15. Paul Hastings believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, the Interim Compensation Procedures Order, 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* Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 19 of 700

Larger Chapter 11 Cases (the "U.S. Trustee Guidelines").4 Paul Hastings respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 16. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains disclosures regarding "customary and comparable compensation." - Exhibit B1 contains a summary of Paul Hastings' timekeepers included in this Application. - Exhibit B2 contains a summary of Paul Hastings' timekeepers who billed less than five (5) hours during the Fee Period and for whom Paul Hastings is not seeking allowance or payment at this time. - Exhibit C contains a summary of the compensation requested by project category. - Exhibit D contains a summary of the compensation requested by Matter ID. - Exhibit E contains the expense reimbursements requested by category. - Exhibit F contains the monthly statements of Paul Hastings detailing the services performed and itemizing the expenses incurred during the Fee Period. - Exhibit G contains the Proposed Order.

17. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed with the

Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

18. On March 21, 2022, the United States Trustee appointed an Official Committee of

Unsecured Creditors ("Committee") in the Individual Debtor's chapter 11 case. No examiner

has been appointed in the Individual Debtor's chapter 11 case.

4 Paul Hastings 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. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 20 of 700

19. On June 15, 2022, the Court entered a memorandum of decision and order [Docket No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the chapter 11 case of Ho Wan Kwok. 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 chapter 11 case of Ho Wan Kwok.

20. The Court authorized Paul Hastings' retention as attorneys for the Trustee pursuant to the *Order Authorizing and Approving the Retention and Employment of Paul Hastings LLP as Counsel to Chapter 11 Trustee, effective as of July 8, 2022* [Docket No. 668] (together with the retention order with respect to the Genever Debtors [Docket No. 1376], the "Retention Order"), entered on August 2, 2022. The Retention Order authorizes Paul Hastings 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 Bankruptcy Rules, and such orders as the Court may direct. Moreover, at the August 1, 2022 hearing on the Paul Hastings' retention application, the Court made clear that it approved Paul Hastings' New York rate structure.5 In addition, as noted on the record at that hearing, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

21. In light of the Trustee's ongoing investigation into the Individual Debtor's assets and his financial affairs, the Trustee is unable at this time to predict when he will be in a position to file a plan and disclosure statement. All quarterly fees have been paid to the United States

5 See Aug. 1, 2022 H'rg Tr. at 113:15-19 ("MR. DESPINS: But I want to be clear is that that's not going to be a back door way to bring local rates, or anything like that -- THE COURT: No, I'm not doing that. I agree with that."). Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 21 of 700

Trustee, and all monthly operating reports have been filed through August 2024 (for each of the Individual Debtor's chapter 11 case, Genever (BVI)'s chapter 11 case, and Genever (US)'s chapter 11 case).

22. At this time, the amount of cash in the Trustee's account is approximately \$72.6 million. The Trustee is not aware of any material administrative expense claims other than claims for professional fees and expenses.

23. On October 11, 2022, Genever (BVI)—an entity wholly owned by the Individual Debtor—filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

24. No trustee or official committee of unsecured creditors has been appointed in Genever (BVI)'s chapter 11 case.

25. October 14, 2022, the Court entered an order granting joint administration of the Individual Debtor's chapter 11 case and Genever (BVI)'s chapter 11 case [Docket No. 970].

26. On January 24, 2023, the Court granted Genever (BVI)'s application to retain Paul Hastings as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., October 11, 2022 [Docket No. 1376].

27. On October 12, 2020, Genever Holdings LLC -- an entity wholly owned by Genever (BVI) -- filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code in the United States Bankruptcy Court for the Southern District of New York (the "SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG) (the "SDNY Bankruptcy Case"). Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 22 of 700

28. On November 3, 2022, the SDNY Bankruptcy Court entered an order [Docket No. 225 in Case No. 22-50592] transferring the venue of the SDNY Bankruptcy Case to this Court, which assigned it Case Number 22-50592.

29. On November 21, 2022, the Court entered an order granting joint administration of the Genever (US) Debtor's chapter 11 case with the jointly administered cases of the Individual Debtor and the Genever (BVI) Debtor's chapter 11 case [Docket No. 1141].

30. On January 24, 2023, the Court granted Genever (US)'s application to retain Paul Hastings as counsel to Genever (US) in its chapter 11 case, effective as of the order transferring venue of the SDNY Bankruptcy Case to this Court, i.e., November 3, 2022 [Docket No. 1376].

31. By this Application, the Trustee and Paul Hastings request allowance of fees (in the amount of \$5,053,513.53) and expenses incurred (in the amount of \$165,738.27) for services rendered by, for, and on behalf of the Trustee during the Fee Period. The Trustee has approved the amounts requested by Paul Hastings herein.

32. While this Application seeks allowance of all fees incurred during the Fee Period, Paul Hastings does not seek, at this time, payment of the 20% holdback withheld by the Debtors' estates with respect to Fee Period. Moreover, as noted, Paul Hastings has not yet been paid with respect to its monthly fee statements for the months of June and July 2024. For the avoidance of doubt, 80% of the fees and all expenses incurred for services provided during the Fee Period may be paid in accordance with the Interim Compensation Procedures Order.6

6 Through this Application, Paul Hastings it is not seeking allowance of fees or reimbursement of expenses with respect to the Civil RICO Adversary Proceeding. Paul Hastings intends to seek payment and allowance of its fees and expenses with respect to the Civil RICO Adversary Proceeding in the future.

33. To date, the Trustee and Paul Hastings have submitted the following fee/expense-

related applications in these chapter 11 cases:

- (a) On March 1, 2023, Paul Hastings submitted the *First Interim Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Reimbursement of Expenses for the Period from July 8, 2022 through October 31, 2022* [Docket No. 1495] (the "Expense Reimbursement Application"), whereby the Trustee and Paul Hastings requested reimbursement of the actual and necessary expenses incurred by the Trustee and Paul Hastings during the period from July 8, 2022 through October 31, 2022 in the amount of \$63,631.75. On May 3, 2023, the Court entered an order granting the Expense Reimbursement Application [Docket No. 1747] (the "Expense Reimbursement Order"). The Individual Debtor's estate paid the foregoing amount on May 8, 2023. - (b) On April 10, 2023, Paul Hastings submitted the Special Fee Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Services Rendered in Securing Compliance with Court-Authorized Subpoenas [Docket No. 1648] (the "Special Fee Application"). In the Special Fee Application, Paul Hastings requested allowance and payment of fees in the amount of \$83,370.26 in accordance with the HK Parties Contempt Order.7 On April 21, 2023, the Court approved the Special Fee Application and ordered the HK Parties to remit payment of \$83,370.26 to the chapter 11 estate of the Individual Debtor [Docket No. 1693] (the "HK Parties Sanctions Order"). The United States District Court for the District of Connecticut has affirmed the HK Parties Sanctions Order. In July 2024, the Trustee received payment in the amount of \$83,370.26 from one of the HK Parties. - (c) On May 30, 2023, Paul Hastings submitted the *Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 8, 2022 through February 28, 2023* [Docket No. 1831] (the "First Interim Fee Application") seeking \$12,326,802.00 in fees and \$348,813.54 for reimbursement of expenses. The First Interim Fee Application excluded the expense reimbursements approved in the Expense Reimbursement Order. The First Interim Fee Application included the amount requested in the Special Fee

7 On March 10, 2023, the Court entered the *Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC* [Docket No. 1537] (the "HK Parties Contempt Order"), pursuant to which the Court ordered Ms. Mei Guo, HK International Funds Investments (USA) Limited ("HK USA"), attorney Lee Vartan, and Chiesa Shahinian & Giantomasi PC (collectively, the "HK Parties"), jointly and severally, to compensate the Trustee and his counsel, Paul Hastings, for reasonable attorneys' fees and expenses associated with the Trustee's efforts to secure compliance with certain Courtauthorized subpoenas.

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 24 of 700

> Application (for the period through February 28, 2023).8 Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$550,000. On June 29, 2023, the Court approved the First Interim Fee Application [Docket No. 1964] with such reduction. Paul Hastings has received payment of \$11,776,802.00 in fees and \$348,813.54 in expenses in connection with the First Interim Fee Application.

- (d) On August 4, 2023, Paul Hastings submitted the *Second Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from March 1, 2023 through June 30, 2023* [Docket No. 2051] (the "Second Interim Fee Application") seeking \$8,037,720.00 in fees and \$213,914.83 for reimbursement of expenses. The Second Interim Fee Application included the amount requested in the Special Fee Application (for the period from March 1, 2023 through March 10, 2023). Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$55,000.00. On September 12, 2023, the Court approved the Second Interim Fee Application [Docket No. 2190] with such reduction. Paul Hastings has received payment of \$6,386,176.00 in fees (or 80% of the allowed fees in the amount of \$7,982,720) and \$213,914.83 in expenses in connection with the Second Interim Fee Application. - (e) On October 16, 2023, Paul Hastings submitted the *Third Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 1, 2023 through August 31, 2023* [Docket No. 2256] (the "Third Interim Fee Application") seeking \$3,725,984.25 in fees and \$146,137.57 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$200,000.00. On November 30, 2023, the Court entered an order [Docket No. 2408] approving the Third Interim Fee Application with such reduction. Paul Hastings has received payment of \$2,820,787.409 in fees (or 80% of the allowed fees in the amount of \$3,525,984.25) and \$146,137.57 in expenses in connection with the Third Interim Fee Application. - (f) On February 19, 2024, Paul Hastings submitted the *Fourth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from September 1, 2023 through December 31, 2023* [Docket No. 2935] (the "Fourth Interim Fee Application") seeking \$6,911,034.50 in fees and \$718,236.31 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$192,930.00 and its expense reimbursement request by \$3,518.70. On March 21, 2024, the Court entered an order [Docket No. 3031] approving the Fourth Interim Fee Application

8 Given that the Trustee was able to recover the fees under the HK Parties Sanctions Order from the HK Parties, Paul Hastings is not seeking further payment of such fees from the estates.

9 Pursuant to the Interim Compensation Procedures Order, Paul Hastings had previously received \$2,980,787.40 in payments for fees incurred in July and August, 2023. Accordingly, as part of its September 2023 monthly fee statement, Paul Hastings included a credit of \$160,000.00 (i.e., 80% of the agreed-upon \$200,000.00 reduction).

with such reductions. Paul Hastings has received payment of \$5,374.483.60 in fees (or 80% of the allowed fees in the amount of \$6,718,104.50) and \$714,717.61 in expenses in connection with the Fourth Interim Fee Application.

- (g) On June 24, 2024, Paul Hastings submitted the Fifth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from January 1, 2024 through March 31, 2024 [Docket No. 3283] (the "Fifth Interim Fee Application") seeking \$4,141,700.76 in fees and \$262,633.83 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$104,700.00 and its expense reimbursement request by \$3,422.52. On July 26, 2024, the Court entered an order [Docket No. 3357] approving the Fifth Interim Fee Application with such reductions. Paul Hastings has received payment of \$3,229,600.5610 in fees (or 80% of the allowed fees in the amount of \$4,037,000.70) and \$259,211.31 in expenses in connection with the Fifth Interim Fee Application. - (h) Pursuant to the Interim Compensation Procedures Order, Paul Hastings submitted monthly fee statements for services rendered during the Fee Period (other than with respect to the Civil RICO Adversary Proceeding). See Docket Nos. 3537, 3538, 3665, and 3666. In particular, Paul Hastings requested: - i. for April 2024 services, fees in the amount of \$876,115.95 (i.e., 80% of \$979,822.80 in fees incurred less a credit of \$103,706.85) and \$61,147.90 (i.e., 100% of \$64,570.42 in expenses incurred less a credit of \$3,422.52) in expenses;11 - ii. for May 2024 services, fees in the amount of \$1,032,578.82 (i.e., 80% of \$1,290,723.5312 in fees incurred) and \$56,812.16 in expenses; - iii. for June 2024 services, fees in the amount of \$913,564.80 (i.e., 80% of \$1,141,956.0013 in fees incurred) and \$30,758.87 in expenses; and

10 Pursuant to the Interim Compensation Procedures Order, Paul Hastings had previously received \$3,333,307.41 in payments for fees incurred in January, February, and March 2024. Accordingly, as part of its April 2024 monthly fee statement, Paul Hastings included a credit of \$103,706.85.

11 As detailed in the Fifth Interim Fee Order, Paul Hastings included a credit in the amount of \$107,129.37 in its April 2024 monthly fee statement, which amount reflects the difference between (a) the fees and expenses previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of January, February, and March 2024 (i.e., \$3,595,941.24) and (b) the fees and expenses that the estates are authorized to pay pursuant to paragraph 3 of the Fifth Interim Fee Order (i.e., \$3,488,811.87). Of that \$107,129.37 credit, \$103,706.85 relates to a reduction in fees, and \$3,422.52 related to a reduction in expenses.

12 This amount reflects a voluntary write-off in the amount of \$98,806.22 in fees incurred related to document review.

13 This amount reflects a voluntary write-off in the amount of \$59,707.50 in fees incurred related to document review.

iv. for July 2024 services, fees in the amount of \$1,128,137.20 (i.e., 80% of \$1,410,171.5014 in fees incurred) and \$13,596.82 in expenses.

Paul Hastings has received payment in the amount of the amount of \$937,263.85 in fees and \$1,089,390.98 in expenses with respect to its monthly fee statements for April and May 2024. As noted, Paul Hastings has not yet received payment with respect to its June and July 2024 services.

34. Except as set forth above, neither the Trustee nor Paul Hastings has received any payment or promise of payment from any source for services rendered during the Fee Period. There is no agreement or understanding between the Trustee and/or Paul Hastings and any other person other than the attorneys, employees, and staff of Paul Hastings, for the sharing of compensation to be received for services rendered in these chapter 11 cases.

35. Paul Hastings' professional services during the Fee Period required an aggregate expenditure of 4,006.8 recorded hours by attorneys and paraprofessionals, broken down as follows: partners (725.9 hours), of counsel (362.1 hours), associates (2,524.7 hours), and paraprofessionals (394.1 hours). The timekeepers who rendered such services are identified in the Cover Sheet hereto, along with the number of hours and the total compensation sought for each individual.

36. Paul Hastings maintains computerized records, in the form of monthly statements, of the time spent by all Paul Hastings' attorneys and paraprofessionals in connection with its representation of the Trustee and the Genever Debtors. With the exception of the monthly statements submitted with the Special Fee Application,15 the monthly statements are in the same form regularly used by Paul Hastings to bill its clients for services rendered and include the date

14 This amount reflects a voluntary write-off in the amount of \$7,975.00 in fees incurred related to document review.

15 As noted in the Special Fee Application, Paul Hastings' monthly statements for fees incurred in securing compliance with the Court-authorized subpoenas are limited to those services and, thus, vary in form from that regularly used by Paul Hastings to bill its clients for services rendered. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 27 of 700

that the services were rendered, a detailed, contemporaneous narrative description of the services provided, the amount of time spent for each service, and the designation of the professional who performed the service. Attached hereto as Exhibit F are true and correct copies of the monthly statements of Paul Hastings related to the fees requested herein.

37. As a courtesy to these estates and based on circumstances unique to these chapter 11 cases, Paul Hastings agreed on a reduced hourly rate for Luc Despins (from his standard hourly rate of \$2,225.00 to the reduced hourly rate of \$1,975.00) for the Fee Period.16 Other than this discount, the rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. In addition, when Paul Hastings' restructuring professionals and paraprofessionals work on non-bankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable non-bankruptcy cases in a competitive national legal market.

38. Paul Hastings respectfully submits that the reasonable value of the services rendered by Paul Hastings (including the Trustee) during the Fee Period is \$5,055,548.53.

39. During the Fee Period, Paul Hastings assisted and advised the Trustee and the Genever Debtors on a regular basis regarding legal matters relating to these chapter 11 cases and the pursuit and recovery of estate assets for the benefit of the chapter 11 estates and their creditors. In addition, Paul Hastings prepared various motions, applications, proposed orders, and other pleadings submitted to the Court for consideration, and performed the necessary

16 This translates into a voluntary waiver of \$70,887.50. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 28 of 700

professional services that are described below and in the fee statements attached hereto and incorporated herein by reference.17

40. For ease of reference and transparency purposes, and at the request of the U.S. Trustee, Paul Hastings created the following separate Matter IDs for services in these chapter 11 cases, including separate Matter IDs for the major adversary proceedings pending in these chapter 11 cases.

00001 General Chapter 11 Trustee Representation 00002 Asset Recovery Investigation and Litigation

17 The description of services in this Application is limited to those matters in which Paul Hastings provided five (5) or more hours of service during the Fee Period.

18 Not included as part of this Application.

19 Not included as part of this Application.

20 Not included as part of this Application. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 29 of 700

41. Additionally, the Trustee and the Genever Debtors retained NPM as their local and conflicts counsel in order to provide services to the Trustee and the Genever Debtor's estates in a cost-effective manner. In particular, as detailed in the NPM retention application and related declarations, Paul Hastings and NPM have coordinated, and will continue to coordinate, each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. Among other things, during the Fee Period, the following matters were delegated to NPM:

- Assisting with filings and service of pleadings in the main chapter 11 case and related adversary proceedings; - Preparing supplemental motions for discovery under Bankruptcy Rule 2004 (including for discovery targets for which Paul Hastings is conflicted), conducting meet and confers with discovery targets, and reviewing documents produced in response to Rule 2004 subpoenas; - Assisting the Trustee on matters on which Paul Hastings is conflicted; - Preparing certain procedural motions, including motion to seal, motions to expedite, and motions to adjourn; - Advising the Trustee and the Genever Debtors on matters related to local Connecticut rules; - Preparing monthly operating reports for the Genever Debtors; and - Performing a variety of case administration functions, including interacting with the Court and the clerks' office as needed, preparing certificates of service, coordinating logistics for hearings, and handling other case administration functions as they arise from time to time.

42. In addition, Paul Hastings has also delegated to NPM a number of important matters—including entire adversary proceedings, such as the Mei Guo Adversary Proceeding (as defined below)—related to the Trustee's investigation and efforts to recover assets for the benefit of these estates. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 30 of 700

43. Finally, Paul Hastings notes that, through this Application, it is not seeking allowance of fees or reimbursement of expenses with respect to the Civil RICO Adversary Proceeding. As the Court is aware, on February 15, 2024, the Trustee filed a complaint alleging that, since at least 2015, the Individual Debtor and various of his associates have operated a racketeering enterprise through an extensive worldwide network of shell companies with the goal of enriching the Individual Debtor, his family members, and his close associates, while concealing the true nature and extent of the Individual Debtor's wealth from his creditors and preventing them from being repaid. Paul Hastings intends to seek payment and allowance of its fees and expenses with respect to the Civil RICO Adversary Proceeding in the future. I. General Chapter 11 Trustee Representation (Matter ID 00001)

i. Case Administration (Task Code B110) Fees: \$146,890.00 Total Hours: 147.10

44. During the Fee Period, Paul Hastings attorneys handled numerous case

administrative matters in connection with these chapter 11 cases, including (a) developing shortterm and long-term strategies for recovering assets for the benefit of these estates, (b) maintaining a case calendar and task lists of open matters and work streams, (c) handling calls and correspondence with the U.S. Trustee and PAX regarding the background to, and the administration of, these chapter 11 cases, and (d) holding internal team meetings and calls to coordinate work streams.

ii. Pleadings Review (Task Code B113) Fees: \$99,399.00 Total Hours: 175.70

45. During the Fee Period, Paul Hastings attorneys and paraprofessionals reviewed and monitored the docket of these chapter 11 cases, the related adversary proceedings (of which there are now more than 300), and pending state court litigation, as well as reviewed pleadings filed therein, as necessary.

- iii. Court Hearings (Task Code B155) Fees: \$16,209.00 Total Hours: 14.30 - 46. During the Fee Period, Paul Hastings attorneys prepared for and attended

numerous hearings and status conferences. The following hearings were recorded under Matter

ID 00001, among others:

- the June 18, 2024 hearing on fee application of Paul Wright and Peter Shaw KC (collectively, the "UK Barristers"); and - the July 23, 2024 hearing on the fee applications of, among others, Eisner Advisory Group LLC ("Eisner"), Epiq Corporate Restructuring, LLC ("Epic"), Kroll, LLC ("Kroll"), Pallas Partners LLP ("Pallas"), O'Sullivan McCormack Jensen & Bliss PC ("OMJB"), Harney Westwood & Riegels LP ("Harneys"), Prager Dreifuss AG ("Prager"), and Paul Hastings.

47. In addition, as detailed below, attendance at several other hearings during the Fee

Period were recorded under the applicable Matter ID. That said, general hearing preparation (including agendas) for the various hearings scheduled in April, May, June, and July 2024 was also recorded under Matter ID 00001.

iv. Fee / Employment Applications for Paul Hastings (Task Code B160) Fees: \$92,774.00 Total Hours: 58.00

48. During the Fee Period, in connection with Paul Hastings' retention, Paul Hastings attorneys prepared and submitted a supplemental declaration with respect to the Trustee's and Paul Hastings' disinterestedness [Docket No. 3209] and continued to research possible connections between the Trustee and Paul Hastings, on the one hand, and parties in interest in these chapter 11 cases, on the other hand. In addition, Paul Hastings attorneys prepared (a) the Fifth Interim Fee Application [Docket No. 3283] (which the Court granted on July 26, 2024 [Docket No. 3357]), and (b) Paul Hastings' monthly fee statements for services rendered in January, February, March, April, and May, 2024. Paul Hastings also corresponded and engaged in discussions with the U.S. Trustee to address questions regarding the above fee and expense Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 32 of 700

reimbursement requests. Among other things, Paul Hastings consensually resolved the U.S. Trustee's informal comments to the Fifth Interim Fee Application.

v. Fee / Employment Applications for Other Professionals (Task Code B165) Fees: \$57,323.00 Total Hours: 34.80

49. During the Fee Period, Paul Hastings attorneys prepared the Trustee's application to retain Harneys as Cayman Islands counsel to the Trustee, which application was filed on May 10, 2024 [Docket No. 3178] (and granted on March 28, 2024 [Docket No. 3219]).

50. In addition, during the Fee Period, Paul Hastings attorneys handled various other fee-related issues, including (a) assisting UK Barristers, Eisner, Kroll, Pallas, OMJB, Harneys, Prager, and Epic with preparing their interim fee applications [Docket Nos. 3188, 3274, 3276, 3277, 3279, 3280, 3281, 3284], (b) reviewing the interim fee applications of NPM, (c) reviewing various fee statements and assisting Prager with preparing its monthly fee statements [Docket Nos. 3232].

vi. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$7,381.25 Total Hours: 7.90

51. During the Fee Period, Paul Hastings attorneys traveled to Bridgeport,

Connecticut, for the April 23, 2024 and July 9, 2024 hearings.

vii. Business Operations (Task Code B210) Fees: \$26,126.00 Total Hours: 20.90

52. During the Fee Period, Paul Hastings attorneys assisted the Trustee with various

matters related to the operation of these chapter 11 estates, including handling wire transfers.

- viii. Financial Reports (Monthly Operating Reports) (Task Code B211) Fees: \$14,660.50 Total Hours: 11.30 - 53. During the Fee Period, Paul Hastings attorneys prepared the monthly operating

reports in the Individual Debtor's chapter 11 case. In the interest of minimizing costs, the

monthly operating reports for the Genever Debtors were prepared by NPM, and any time spent Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 33 of 700

by Paul Hastings attorneys reviewing and commenting such reports was recorded under Matter ID 00010 (for Genever (US)) and 00011 (for Genever (BVI)). II. Asset Recovery Investigation and Litigation (Matter ID 00002)

i. Court Hearings (Task Code B155) Fees: \$19,318.50 Total Hours: 10.40

54. During the Fee Period, Paul Hastings attorneys prepared for numerous hearings and status conferences regarding the Trustee's investigation and related litigation. The following hearings were recorded under Matter ID 00001, among others:

> the May 28, 2024 hearing on the Trustee's motion regarding transfer of ownership of the Ducati motorcycle

55. As detailed further below, attendance at these various hearings was generally recorded under the Matter ID for the applicable adversary proceeding. That said, attendance at the April 23, 2024 hearing on the Trustee's motion to modify procedures applicable to avoidance actions and the Trustee's motion for default judgment in the HCHK Adversary Proceeding was recorded under this matter number, i.e., Matter ID 00002.

ii. General Litigation (Task Code B191) Fees: \$292,608.51 Total Hours: 237.80

56. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's motion [Docket No. 3177], where the Trustee requested, upon consent of Mr. Scott Barnett, the purported owner of the Ducati motorcycle, the transfer of ownership of Ducati motorcycle to the estate. The Court granted the motion on May 28, 2024 [Docket No. 3220], holding the Ducati motorcycle is exclusively property of the estate to be administered by the Trustee.

57. Paul Hastings attorneys also assisted NPM in preparing the Trustee's motion for order modifying the October 6, 2022 protective order and designating bank statements Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 34 of 700

previously designated "Highly Confidential" as "Confidential" [Docket No. 3213], which motion the Court granted on June 20, 2024 [Docket No. 3264].

58. Paul Hastings attorneys also assisted NPM in preparing the Trustee's motion to extend deadline to file avoidance actions to February 15, 2025 [Docket No. 3329] (the "Further Tolling Motion"). The Trustee filed the Further Tolling Motion because, despite the diligent efforts of the Trustee and his professionals, and the significant and important progress and success he has already made, the enormity of the Trustee's task and the constant obstruction he faced, coupled with the delay caused by the Criminal Trial which also revealed important information the Trustee had not learned in discovery, rendered it impossible for him to complete his investigation and bring all available causes of action prior to August 15, 2024 (i.e., the extended deadline pursuant to the Court's order on February 15, 2024). The Court granted the Trustee's motion on August 14, 2024.

59. In addition, Paul Hastings attorneys continued to (a) analyze and coordinate service on international defendants in various adversary proceedings, (b) conduct research on pertinent legal questions relating to issues in the Trustee's current litigation and investigations, analyze enforcement of judgment in foreign jurisdictions, and (c) prepare pleadings to recover additional assets for the estate.

iii. Investigations (Task Code B261) Fees: \$1,314,034.49 Total Hours: 1028.50

60. During the Fee Period, Paul Hastings attorneys continued to handle the Trustee's investigation to identify potential assets of the Individual Debtor's estate. Given the corporate maze of shell companies set up by the Individual Debtor, including hundreds of companies purportedly owned by his close family members, business associates, and employees, this investigation has necessarily been extensive and time intensive. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 35 of 700

61. As part of this investigation, Paul Hastings attorneys (a) analyzed documents produced in response to Rule 2004 subpoenas,21 (b) engaged in meet and confer sessions with the targets of the Rule 2004 discovery, (c) identified additional entities for further investigation, (d) conducted numerous calls and meetings with the Trustee's forensic accountant (Kroll) to advance the Trustee's investigation concerning potential estate claims, (e) analyzed potential claims against the Individual Debtor and his affiliated entities, (f) assisted the Trustee's Swiss counsel (i.e., Prager) in preparing an application to have the Individual Debtor's chapter 11 case recognized in Switzerland (in order to further advance the Trustee's investigation as to estate property located in Switzerland), and (g) analyzed exhibits and testimony from the Criminal Trial.

62. Paul Hastings attorneys also continued to assist NPM in preparing supplemental motions under Bankruptcy Rule 2004 seeking discovery from various individuals and entities associated with the Individual Debtor, including fifteenth supplemental motions filed on May 16, 2024 [Docket No. 3193].22 The Court granted this Rule 2004 motion [Docket No. 3223]. Furthermore, during the Fee Period, Paul Hastings attorneys continued to communicate with confidential informants, who provided valuable insight into the Individual Debtor's business operations.23

21 As further detailed below, in the interest of minimizing costs, Paul Hastings utilized UnitedLex Corporation ("UnitedLex") to conduct, among other things, first-round review of documents produced in the Trustee's investigation. UnitedLex specializes in discovery services, including document processing, storage, review services, and distribution.

22 The supplemental Rule 2004 motions were filed by NPM because Paul Hastings was conflicted as to some of the discovery targets. To the extent Paul Hastings did not have a conflict, it assisted NPM in preparing the supplemental motion.

23 In light of the Individual Debtor's well-documented social media campaign against the Trustee, Paul Hastings attorneys, and creditors in these chapter 11 cases, the time entries attached to this Application have been redacted to remove the names of these informants. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 36 of 700

63. As noted in Paul Hastings' prior fee applications, much of the Trustee's investigation also required the expertise of Paul Hastings' Mandarin-speaking attorneys in order to analyze thousands Mandarin-language documents (including WhatsApp, text messages, and videos). This work required not only Mandarin language skills but an understanding of the legal significance of these documents, which an outside translation service would not be able to provide. Paul Hastings' Mandarin-speaking attorneys were also critical for the Trustee to communicate with the numerous Mandarin-speaking informants that have reached out to the Trustee during the course of these chapter 11 cases.

64. To date, the Trustee's investigation (including as a result of discovery under Rule 2004, information provided by confidential informants, and corporate documents received from BVI registered agents) uncovered numerous assets that the Trustee believes are property of the Individual Debtor's estate, which the Trustee is seeking to recover for the benefit of the estate. In fact, as detailed further below, during the Fee Period, the Trustee continued to prosecute several adversary proceedings to recover such assets.

65. Unfortunately, as the Court is well aware, the Trustee's investigation continued to face vigorous opposition, at every turn, not only from the Individual Debtor, but also many of the targets of the Trustee's investigation (i.e., the Individual Debtor's close family members, business associates, and employees), necessitating further motion practice.

i. Court Hearings (Task Code B155) Fees: \$116,985.50 Total Hours: 114.30

66. During the Fee Period, Paul Hastings attorneys attended (a) the change-of-plea hearing of Yvette Wang during which she pleaded guilty to two counts of conspiracy to commit Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 37 of 700

wire fraud and conspiracy to commit money laundering, (b) the final pre-trial conference in the Individual Debtor's Criminal Case, and (c) the Individual's Debtor's Criminal Trial.

ii. General Litigation (Task Code B191) Fees: \$404,454.50 Total Hours: 297.60

67. During the Fee Period, Paul Hastings attorneys assisted the Trustee on various litigation-related matters (other than the adversary proceedings pending in these chapter 11 cases), including the Criminal Case. Among other things, Paul Hastings monitored the Criminal Case, responded to the U.S. government's grand jury subpoena, analyzed various issues related to forfeiture, analyzed pleadings filed in the Criminal Case, attended the Individual Debtor's Criminal Trial, and analyzed transcripts and exhibits of the Criminal Trial.

68. On May 3, 2024, the Individual Debtor's co-defendant and chief of staff Yvette Wang pleaded guilty to one count of conspiracy to commit wire fraud and one count of conspiracy to commit money laundering. The statutory maximum term of imprisonment on the two counts is ten years.

69. The Individual Debtor's Criminal Trial commenced on May 22, 2024. On July 16, 2024, a unanimous jury found the Debtor guilty on nine of the 12 charges, including racketeering conspiracy, conspiracy to commit wire fraud and bank fraud, money laundering conspiracy, conspiracy to commit securities fraud, and multiple wire fraud and securities fraud charges.

70. Finally, during the Fee Period, Paul Hastings attorneys also prepared and filed numerous notices to apprise this Court and parties in interest of the developments in the Criminal Case, including with respect to (a) the U.S. government's letter in response to Yvette Wang's Rule 16 motion, (b) Yvette Wang's guilty plea, and (c) the Individual Debtor's guilty verdict. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 38 of 700

- iii. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$15,112.50 Total Hours: 28.20 - 71. During the Fee Period, Paul Hastings attorneys traveled to the United States

District Court for the Southern District of New York to attend (a) the change-of-plea hearing of Yvette Wang during which she pleaded guilty to two counts of conspiracy to commit wire fraud and conspiracy to commit money laundering, (b) the final pre-trial conference in the Individual Debtor's Criminal Case, and (c) the Individual's Debtor's Criminal Trial.

i. Tax Issues (Task Code B240) Fees: \$20,595.50 Total Hours: 13.30

72. During the Fee Period, Paul Hastings attorneys continued to confer with the Trustee's tax advisors (i.e., Eisner Advisory Group LLC, "EA Group") regarding the preparation of tax filings for the Debtors. Among other things, Paul Hastings attorneys addressed questions by EA Group regarding various transactions during these chapter 11 cases, as well as coordinated with EA Group regarding the filing of tax extension forms.

i. Asset Disposition (Task Code B130) Fees: \$15,418.00 Total Hours: 13.30

73. During the Fee Period, Paul Hastings attorneys continued to analyze how best to monetize the furniture located at the Sherry Netherland Apartment. In light of the need to conduct the soot cleaning project on an expeditious basis, Genever (US) first moved the furniture into storage. ii. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$6,410.00 Total Hours: 8.80

74. During the Fee Period, Paul Hastings attorneys traveled to the Sherry Netherland Apartment to discuss and oversee the remediation and cleaning projects, traveled to and from Branchburg, New Jersey to oversee moving of furniture from the Sherry Netherland Apartment,

iii. Business Operations (Task Code B210) Fees: \$171,631.50 Total Hours: 120.90

75. During the Fee Period, Paul Hastings attorneys analyzed various operational matters with respect to Genever (US), including, most notably, as it relates to the remediation and cleaning work for the Sherry Netherland Apartment, including the cleaning of soot and other combustion by-products ("CBPs"). Paul Hastings attorneys prepared Genever (US)'s motion to remediate soot, char, and other CBPs in the Sherry Netherland Apartment as a result of a fire on March 15, 2023, including related ancillary services, such as abating asbestos in the affected areas, moving furniture into storage, and disposing of certain items of inconsequential value [Docket No. 3128], which motion the Court granted by order dated May 6, 2024 [Docket No. 3168].24

76. Among other things, Paul Hastings attorneys (a) worked closely with the architect (Acheson Doyle) regarding progress of the remediation and cleaning projects, (b) prepared the monthly status reports in accordance with the Court's order, dated September 19, 2023 [Docket No. 2213]. In anticipation of completing the remediation and cleaning work at the Sherry Netherland Apartment, Paul Hastings attorneys also engaged with Sotheby's to discuss marketing of the Sherry Netherland Apartment

24 In light of the Sherry Netherland's concerns that CBPs could potentially cross-contaminate other apartments or common areas in the buildings—via interstitial spaces, chases, plenums, air bands, and elevators, Genever US determined to proceed with the cleaning project. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 40 of 700

iv. Financing/Cash Collections (Task Code B230) Fees: \$39,093.50 Total Hours: 22.70

77. During the Fee Period, Paul Hastings attorneys prepared and filed joint motion of the Trustee, Genever US and Genever BVI for order authorizing amendment to interdebtor postpetition financing agreement [Docket No. 3259] to increase the borrowing limit from \$2 million to \$3 million—so as to be able to fund the cost of the additional necessary cleaning of the Sherry Netherland Apartment. The Court granted the motion on July 18, 2024 [Docket No. 3325].

i. General Litigation (Task Code B191) Fees: \$19,635.50 Total Hours: 12.00

78. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC [Adv. Proc. No. 23-05017] (the "Mahwah Adversary Proceeding"). In the Mahwah Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the Debtor is the equitable owner of the 50,000 square foot Mahwah Mansion, (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to Mahwah Mansion), and (c) that Taurus Fund, LLC is an alter ego of the Individual Debtor.

79. Following the conclusion of the Individual Debtor's Criminal Trial, Paul Hastings attorneys prepared and filed on August 1, 2024 the Trustee's notice of resumption of the Mahwah Adversary Proceeding [Docket No. 37 in Adv. Proc. No. 23-05249], which was stayed pursuant to the Court's order on February 2, 2024 [Docket No. 102 in Adv. Proc. No. 23-05017].

80. During the Fee Period, Paul Hastings attorneys (a) handled issues in connection with Taurus Fund ceasing to pay expenses related to maintenance of the Mahwah Mansion Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 41 of 700

following the Individual Debtor's conviction, including seeking (and obtaining) authorization to fund such expenses from the Individual Debtor's estate, (b) prepared for and attended a status conference, and (c) prepared the Trustee's motion for summary judgment. Among other things, the Trustee obtained Court authorization to fund these security and maintenance costs on August 15, 2024 [Docket No. 3422] and filed his motion for summary judgment on September 11, 2024. VII. Golden Spring Adversary Proceeding (Matter ID 00013)

i. General Litigation (Task Code B191) Fees: \$34,215.00 Total Hours: 33.60

81. During the Fee Period, Paul Hastings attorneys continued to handle all aspects of the Trustee's adversary proceeding against Golden Spring and China Golden Spring (the "Golden Spring Entities") [Adv. Proc. No. 23-05018] (the "Golden Spring Adversary Proceeding"). In the Golden Spring Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Golden Spring is the alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Golden Spring and/or its assets (notwithstanding China Golden Spring's purported ownership interest in Golden Spring). As the Court will recall, on December 4, 2023, the Court entered a default judgment against the Golden Spring Entities [Docket No. 35 in Adv. Proc. No. 23-05018] (the "Golden Spring Default Judgment"). Pursuant to the Golden Spring Default Judgment, the Court determined, among other things, that all assets (including, without limitation, all property, rights, interests, and privileges) held by Golden Spring constitute property of the estate, and the Court ordered that all such assets be turned over and/or surrendered to the Trustee. In accordance with this Court's prior order, the contents of Storage Units #1A32 and #CF09 have been moved into separate storage controlled by the Trustee, and the contents Storage Units #CA14 and #CB14 have been moved to the Mahwah Mansion. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 42 of 700

82. During the Fee Period, Paul Hastings attorneys (a) coordinated and oversaw moving of contents from the storage units located in Upper Saddle River, New Jersey, (b) reviewed and analyzed documents and contents of electronic devices recovered from such storage units, and (c) conducted inspection at additional storage units in New York.

ii. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$5,319.00 Total Hours: 10.80

83. During the Fee Period, Paul Hastings attorneys traveled to and from Upper Saddle River, New Jersey to coordinate and oversee moving of contents of the New Jersey storage units—which are property of the estate—to storage warehouse at Branchburg New Jersey. Paul Hastings attorneys also traveled to and from another storage units in New York to inspect the contents of the units.

i. General Litigation (Task Code B191) Fees: \$345,298.00 Total Hours: 271.30

84. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against the HCHK Entities, the Assignee, Holy City Hong Kong Ventures, Ltd., Yvette Wang, and Anthony DiBattista [Adv. Proc. No. 23-05013] (the "HCHK Adversary Proceeding"). In the HCHK Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the HCHK Entities are alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets. In addition, the complaint sought an injunction against the commencement or continuation of the assignment proceedings commenced with respect to the HCHK Entities in New York state court (the "Assignment Proceedings"). In connection with the HCHK Adversary Proceeding, the Trustee also requested and obtained a temporary restraining order as it relates to the commencement or continuation of the Assignment Proceeding [Docket No. 18 in Adv. Proc. No. 23-05013]. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 43 of 700

85. On June 14, 2024, the Court granted the Trustee's motion for default judgment, holding, among other things, that the HCHK Entities are the alter egos of the Individual Debtor and directing that the property of the HCHK Entities be turned over to the estate [Docket No. 290 in Adv. Proc. No. 23-05013]. As a result of this ruling, among other things, over \$38 million of the HCHK Entities' funds (previously transferred into accounts controlled by the Trustee pursuant to the settlement with the Assignee) are now property of the estate.

86. Among other things, during the Fee Period, Paul Hastings attorneys prepared and filed (a) the Trustee's reply in support of his motion for default judgment [Docket No. 283 in Adv. Proc. No. 23-05013], (b) the proposed order granting the Trustee's motion for default judgment [Docket No. 292 in Adv. Proc. No. 23-05013] and response to defendants' partial objection to the proposed order [Docket No. 295 in Adv. Proc. No. 23-05013], (c) the Trustee's consolidated appellee brief in the appeal of this Court's Rule 9019 settlement and intervention order, and (d) the Trustee's consolidated response in opposition to the appellants' motion for stay pending appeal. On September 30, 2024, clerk of the District Court entered a judgment, dismissing with prejudice the proposed intervenors' appeal of this Court's intervention order pursuant to a stipulation by the parties.

87. Moreover, during the Fee Period, Paul Hastings attorneys also, with assistance from UnitedLex, reviewed and analyzed contents of devices belonging to HCHK Entities.

ii. Business Operations (Task Code B210) Fees: \$15,727.00 Total Hours: 12.20

88. During the Fee Period, Paul Hastings attorneys Paul Hastings attorneys worked with the Assignee's counsel to handle administrative matters undertaken pursuant to the settlement agreement (the "Assignee Settlement") between the Trustee and the Assignee. These tasks included, among other things, reviewing the Assignee's business records, analyzing the Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 44 of 700

HCHK Entities' cash holdings, filing expense reports required to be filed under the Assignee Settlement, and handling payments to employees and service providers of the HCHK Entities.

i. General Litigation (Task Code B191) Fees: \$7,417.50 Total Hours: 5.10

89. During the Fee Period, Paul Hastings attorneys continued to assist NPM in prosecuting the Trustee's complaint against Mei Guo [Adv. Proc. No. 22-05008] (the "Mei Guo Adversary Proceeding"). In the Mei Guo Adversary Proceeding, the Trustee seeks (a) an order declaring that the proceeds (the "Bombardier Proceeds") from the sale of the Individual Debtor's private Bombardier jet (the "Bombardier") are property of the estate, (b) an order that Mei Guo surrender the Bombardier Proceeds or the value thereof to the Trustee because she received the Bombardier Proceeds as an unauthorized postpetition transfer avoidable under section 549 of the Bankruptcy Code, (c) an order that Mei Guo surrender to the Trustee the value of the Individual Debtor's shell company Anton Development Limited ("Anton Development") at the time the company was transferred to her on June 27, 2017 (upon which date Anton Development was title holder to the Bombardier) pursuant to a transaction avoidable as an actual fraudulent transfer, and (d) an order declaring that a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate.

90. On April 3, 2024, the Court granted, in part, the Trustee's motion for summary judgment, holding, among other things, that the Individual Debtor beneficially owned the Bombardier and, hence, beneficially owns the Bombardier proceeds and directing Mei Guo to turn over to the estate the Bombardier proceeds [Docket No. 126 in Adv. Proc. No. 22-05008].25

25 On April 17, 2024, Mei Guo appealed this decision to the United States District Court of the District of Connecticut (the "Mei Guo Appeal").

91. Among other things, during the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's counter-designations with respect to Mei Guo's appeal of the foregoing summary judgment ruling as well as analyzed issues relating to obtaining control of Whitecroft Shore Limited in the BVI. X. Greenwich Land Adversary (Matter ID 00020)

- i. General Litigation (Task Code B191) Fees: \$115,294.50 Total Hours: 68.40 - 92. During the Fee Period, Paul Hastings attorneys continued to prosecute the

Trustee's complaint against Greenwich Land and Hing Chi Ngok [Adv. Proc. No. 23-05005] (the "Greenwich Land Adversary Proceeding"). In the Greenwich Land Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Greenwich Land is an alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Greenwich Land. On July 3, 2024, the Court granted the Trustee's motion for summary judgment, holding, among other things, that Greenwich Land is an alter ego of the Individual Debtor and directing that the property of Greenwich Land be turned over to the estate. As a result of this ruling, among other things, the Debtor's multi-million-dollar mansion located at 373 Taconic Road, Greenwich, Connecticut is now property of the estate.

93. During the Fee Period, Paul Hastings attorneys (a) analyzed issues relating to the defendants' motion to stay pending appeal, which motion was resolved upon the Court's entering of the consent order resolving defendants' motion [Docket No. 166 in Adv. Proc. No. 23-05005], (b) prepared and filed the Trustee's request for status conference [Docket No. 152 in Adv. Proc. No. 23-05005], and (c) prepared for and attended a status conference.26 On September 30, 2024,

26 On September 30, 2024, the Trustee filed a motion to sell the Taconic Property for a purchase price of \$6.9 million. The hearing on the sale motion is scheduled for October 15, 2024. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 46 of 700

the Trustee filed a motion to sell the Taconic Property for a purchase price of \$6.9 million. The Trustee subsequently filed a notice to the Court on October 14, 2024 regarding a higher and better offer to purchase the Taconic Property for \$7.25 million. The hearing on the sale motion is scheduled for October 15, 2024 XI. Lamp Capital Adversary (Matter ID 00024)

- i. General Litigation (Task Code B191) Fees: \$158,716.50 Total Hours: 128.20 - 94. During the Fee Period, Paul Hastings attorneys continued to prosecute the

Trustee's adversary proceeding against Lamp Capital LLC and certain other defendants [Adv. Proc. No. 23-05023] (the "Lamp Capital Adversary Proceeding"). In the Lamp Capital Adversary Proceeding, the Trustee seeks determinations that, among other things, Lamp Capital, Hudson Diamond NY LLC, and Leading Shine NY Ltd. are the Individual Debtor's alter egos and that the Individual Debtor equitably owns these alter ego defendants and their assets. On December 14, 2023, the Court entered a default against defendants Lamp Capital, Infinity Treasury, Leading Shine NY, and Yvette Wang [Docket No. 13 in Adv. Proc. No. 23-05023]. On February 15, 2024, Lamp Capital and Infinity Treasury appealed this decision to the United States District Court of the District of Connecticut [Case No. 3:24-cv-00217-KAD] (the "Lamp Capital Appeal").

95. During the Fee Period, Paul Hastings attorneys (a) prepared and filed the Trustee's appellee brief in the Lamp Capital Appeal [Docket No. 20 in Case No. 3:24-cv-00217- KAD], (b) reviewed and analyzed the record related to Hudson Diamond NY LLC and Leading Shine NY Ltd. in connection with Trustee's motion for summary judgment, (c) prepared a motion for summary judgment as to Hudson Diamond NY LLC and Leading Shine NY Ltd., which was filed on September 19, 2024 (i.e., after the Fee Period) [Docket Nos. 97, 98 in Adv. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 47 of 700

Proc. No. 23-05023], and (c) in conjunction with NPM, handled issues relating to liquidation of the VCTR Shares. XII. Ace Decade Adversary Proceeding (Matter ID 00026)

i. Court Hearings (Task Code B155) Fees: \$23,814.50 Total Hours: 12.70

96. During the Fee Period, Paul Hastings attorneys prepared for and attended the July 9, 2024 hearing and the July 16, 2024 hearing on the Trustee's motion for default judgment against Ace Decade and Yvette Wang.

ii. General Litigation (Task Code B191) Fees: \$249,660.00 Total Hours: 159.10

97. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against Ace Decade, Yvette Wang, and Rui Hao [Adv. Proc. No. 23-05028] (the "Ace Decade Adversary Proceeding"). In the Ace Decade Adversary Proceeding, the Trustee seeks declarations that the transfer of the Ace Decade share by defendant Wang to defendant Hao is void in light of this Court's prior ruling that the Trustee beneficially owns the Ace Decade share.

98. During the Fee Period, Paul Hastings attorneys (a) prepared and filed the Trustee's opposition to defendant Wang's motion to reconsider [Docket No. 35 in Adv. Proc. No. 23-05028], which motion was withdrawn on May 8, 2024 [Docket No. 36 in Adv. Proc. No. 23-05028], (b) prepared and filed the Trustee's motion for entry of default judgment as against Ace Decade and Yvette Wang [Docket No. 40 in Adv. Proc. No. 23-05028], which the Court granted on July 22, 2024 [Docket No. 73 in Adv. Proc. No. 23-05028], (c) handled issues relating to the liquidation proceedings with respect to Ace Decade and corresponded with Pallas regarding updates in the Ace Decade Adversary Proceeding, (d) prepared and filed the Trustee's opposition to the BVI joint liquidators' motion to extend time to respond to the Trustee's default Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 48 of 700

judgment motion [Docket No. 51 in Adv. Proc. No. 23-05028], (e) prepared the Trustee's letter to defendant Rui Hao's BVI counsel in connection with the BVI liquidation proceedings, (f) prepared and filed the Trustee's motion for entry of default judgment as against defendant Rui Hao [Docket No. 75 in Adv. Proc. No. 23-05028], which the Court granted on September 12, 2024 (i.e., after the Fee Period), and (g) coordinated service of pleadings on the defendants, including international service on defendant Hao (who resides in Switzerland) in accordance with the Hague Convention, and prepared and filed certificates of service regarding same. On September 12, 2024, the Court also entered a default judgment against Rui Hao.

99. In addition to the foregoing, the Trustee must also seek relief in the BVI to rectify the membership list for Ace Decade to reflect the estate's ownership of Ace Decade. These matters are further complicated by the commencement of liquidation proceedings with respect to Ace Decade (and the appointment of joint liquidators) in the BVI. Paul Hastings is working with the Trustee's BVI counsel (Harneys) to evaluate next steps in this regard. XIII. Defeng Cao Adversary Proceeding (Matter ID 00027)

i. Court Hearings (Task Code B155) Fees: \$12,730.00 Total Hours: 7.10

100. During the Fee Period, Paul Hastings attorneys prepared for and attended the May 14, 2024 hearing on the Trustee's motion for judgment on the pleadings.

ii. General Litigation (Task Code B191) Fees: \$61,114.50 Total Hours: 44.30

101. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Defeng Cao (the long-term boyfriend of the Debtor's daughter) [Adv. Proc. No. 24-05001] (the "Defeng Cao Adversary Proceeding"). In the Defeng Cao Adversary Proceeding, the Trustee seeks to recover six separate vehicles—three Harley Davidsons and one BMW motorcycle, as well as one Land Rover Defender and one Dodge Ram Pickup Truck— Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 49 of 700

which, while nominally held by the defendant, were fraudulently transferred to the defendant, or alternatively, are equitably owned by the Individual Debtor.

102. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's motion for judgment on the pleadings with respect to the four luxury motorcycles which were nominally held by Defeng Cao (the long-term boyfriend of the Debtor's daughter) [Docket No. 19 in Adv. Proc. No. 24-05001]. Paul Hastings attorneys also prepared the Trustee's reply in support of his motion for judgment on the pleadings [Docket No. 25 in Adv. Proc. No. 24- 05001]. On September 9, 2024, the Court granted the Trustee's motion for judgment on the pleadings, holding that the motorcycles are property of the estate and requiring Mr. Cao to turn them over to the estate. XIV. Omnibus Alter Ego Adversary Proceeding (Matter ID 00028)

i. General Litigation (Task Code B191) Fees: \$38,133.00 Total Hours: 28.70

103. During the Fee Period, Paul Hastings attorneys continued to prosecute the adversary proceeding commenced by the Trustee against more than forty entities—each nominally owned by a family member or associate of the Individual Debtor)—seeking rulings that such entities are alter egos of the Individual Debtor and/or their assets are beneficially owned by the Individual Debtor, such that their assets are property of the estate [Adv. Proc. No. 24-05249] (the "Omnibus Alter Ego Adversary Proceeding"). The Omnibus Alter Ego Adversary Proceeding had been stayed pending conclusion of the Individual Debtor's Criminal Trial, except as to the Trustee's claims against defendant K Legacy, Ltd. ("K Legacy") and Qiang Guo in his capacity as nominal owner of K Legacy, pursuant to the Court's order on March 22, 2024 [Docket No. 14 in Adv. Proc. No. 23-05249]. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 50 of 700

104. During the Fee Period, Paul Hastings attorneys, in conjunction with NPM, prepared the Trustee's request for entry of default and subsequently the Trustee's motion for entry of default judgment against the Individual Debtor's son, i.e., Qiang Guo, and K Legacy. On May 17, 2024, the Clerk of the Court entered a default against K Legacy [Docket No. 26 in Adv. Proc. No. 24-5249]. Furthermore, on September 12, 2024, the Trustee obtained entries of default as against K Legacy and Qiang Guo, pursuant to which the Court held, among other things, that the ownership interests in K Legacy and the assets of K Legacy, including a luxury apartment in London, are property of the estate. In addition to obtaining a default judgment against K Legacy and the Debtor's son, the Trustee has also recently commenced proceedings in the BVI, i.e., the jurisdiction where K Legacy is incorporated, to, among other things, rectify K Legacy's membership list and establish the estate's ownership of K Legacy and the London apartment.

105. Following the conclusion of the Individual Debtor's Criminal Trial, Paul Hastings attorneys prepared and filed the Trustee's notice of resumption of the Omnibus Alter Ego Adversary Proceeding [Docket No. 37 in Adv. Proc. No. 23-05249].

106. Furthermore, during the Fee Period, Paul Hastings attorneys continued to analyze legal issues relating to international service and coordinate service of the complaint and summons on the defendants. In connection information and/or exhibits cited in the complaint that has been designated "Confidential" or "Highly Confidential" pursuant to the Protective Order [Docket No. 923], Paul Hastings attorneys also analyzed the confidentiality designation of such exhibits and redaction applied to the complaint.

i. General Litigation (Task Code B191) Fees: \$832,213.96 Total Hours: 593.00

107. During the Fee Period, Paul Hastings attorneys, in conjunction with Kroll and NPM, continued to analyze potential avoidance actions claims (for instance, with respect to professional services firms) and conducted related research. Paul Hastings attorneys assisted NPM with filing additional Avoidance Action complaints. Ultimately, the Trustee has now filed a total of approximately 300 Avoidance Actions seeking the avoidance of fraudulent and postpetition transfers made by the Individual Debtor through his shell companies. In order to minimize costs, the large majority of these complaints were prepared and filed by NPM.

108. Paul Hastings attorneys, in conjunction with NPM, also prepared and filed (a) the Trustee's responses to various Avoidance Action defendants' motions to dismiss, (b) the Trustee's response to motion to file amicus brief in the Avoidance Action involving Weddle Law PLLC, (c) amended Avoidance Action complaints, and (d) analyze other litigation-related issues, including extension of response deadlines and motions to withdraw the reference. Paul Hastings attorneys also prepared the Trustee's motion for judgment on the pleadings with respect to the Trustee's adversary complaint as against Zeisler & Zeisler, P.C.. The motion was filed on August 2, 2024. As discussed above, Paul Hastings attorneys, in conjunction with NPM, prepared the Trustee's motion to extend the August 15, 2024 deadline for the Trustee to commence actions to avoid and recover fraudulent transfers and/or assert other estate causes of action (which motion was filed on July 19, 2024), and related motions to limit service. The Court granted this motion to extend deadline by order dated August 14, 2024.

109. In addition, Paul Hastings attorneys continued to meet and confer with counsel for Avoidance Action defendants and discuss and analyze potential settlements. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 52 of 700

110. Furthermore, Paul Hastings attorneys prepared, in conjunction with NPM, the Trustee's motion (the "Mediation Procedures Motion") to amend the avoidance actions procedures to temporarily stay certain of the recently filed avoidance actions while the Trustee and the respective defendants engage in informal settlement discussions and participate in nonbinding mediation under the supervision of U.S. Bankruptcy Judge James J. Tancredi. The Court granted the Mediation Procedures Motion (with certain revisions) by order, dated May 2, 2024 [Docket No. 3163].

111. Finally, during the Fee Period, Paul Hastings attorneys continued to analyze and coordinate the service of the Avoidance Action complaints on the respective defendants, including international service through the Hague Convention.

i. General Litigation (Task Code B191) Fees: \$296,586.54 Total Hours: 182.70

112. As discussed above, on March 15, 2024, the Trustee filed his Mediation Procedures Motion to amend the avoidance actions procedures to temporarily stay certain of the recently filed avoidance actions while the Trustee and the respective defendants engage in informal settlement discussions and participate in non-binding mediation under the supervision of U.S. Bankruptcy Judge James J. Tancredi. During the Fee Period, Paul Hastings attorneys coordinated with NPM in preparing and filing the Trustee's amended proposed orders [Docket Nos. 3105, 3156], and attended hearing on the Mediation Procedures Motion on April 23, 2024 (which was recorded under Matter ID 00002). The Court granted the Trustee's Mediation Procedures Motion by order on May 2, 2024.

113. Furthermore, to prepare for the mediation, during the Fee Period, Paul Hastings attorneys, in conjunction with NPM, (a) analyzed legal issues and caselaw concerning the Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 53 of 700

mediation and settlement, (b) prepared presentation slides and materials for no less than five mediation presentations held in June and July, 2024, including an introductory presentation and presentations addressing various groups of mediation parties, (c) held discussion with Judge Tancredi, as the mediator, about the mediation processes, and (d) held internal meetings to discuss strategy and analyze case materials in connection with mediation and potential settlements. XVII. Forfeiture Issues (Matter ID 00031)

i. General Litigation (Task Code B191) Fees: \$60,149.00 Total Hours: 32.80

114. In connection with the Individual Debtor's Criminal Case, the U.S. government has seized and sought to forfeit more than \$630 million in various accounts, as well as various other assets controlled by the Individual Debtor (the "Seized Assets") as identified in the third superseding indictment. The Seized Assets and/or the entities in whose name they were held are also subjects of various adversary proceedings commenced by the Trustee. Thus, navigating and resolving forfeiture issues with the U.S. Government is of critical importance to the interest of the estate and of the Individual Debtor's creditors, to whom the Trustee owes a fiduciary duty.

115. In light of the above, during the Fee Period, Paul Hastings attorneys (a) reviewed and analyzed legal issues and case law regarding criminal forfeiture, (b) prepared presentation slides and related materials, and (c) held internal conferences to discuss and strategize.

i. Investigations (Task Code B261) Fees: \$19,661.50 Total Hours: 10.80

116. As discussed above, the Omnibus Alter Ego Adversary Proceeding had been stayed pending conclusion of the Individual Debtor's Criminal Trial, except as to the Trustee's claims against defendant K Legacy and Qiang Guo (in his capacity as nominal owner of K Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 54 of 700

Legacy). During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's claims as against K Legacy and Qiang Guo. A critical aspect of the Trustee's investigation and litigation is to understand the ownership and corporate structure of K Legacy, an entity organized in the BVI and held title to the Individual Debtor's luxury apartment in London.

117. In light of the above, during the Fee Period, Paul Hastings attorneys, in conjunction with the Trustee's BVI counsel, Harneys, prepared disclosure application to the BVI court.

118. 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).27

119. 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

27 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). Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 55 of 700

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).

120. 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., 28 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.29 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,

28 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.

29 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). Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 56 of 700

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

and Johnson as the "leading cases with regard to the factors to be considered in determining a

reasonable allowance of compensation").

121. In accordance with the factors enumerated in section 330 of the Bankruptcy Code

and applicable case law, the amount requested herein by Paul Hastings is fair and reasonable, as

set forth below and otherwise in this Application.

Paul Hastings billed a total of \$5,053,513.53 and 4,006.8 hours of professional and paraprofessional services during the Fee Period. As evidenced by this Application, Paul Hastings professionals and paraprofessionals worked diligently and efficiently without unnecessary duplication of efforts throughout the Fee Period. A small group of the same Paul Hastings attorneys was utilized for the vast majority of the work in order to minimize the costs of intra-Paul Hastings communication and education about the Debtors' circumstances. Whenever possible, Paul Hastings sought to minimize the cost of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. The services were performed in an effective and efficient manner commensurate with the complexity, exigency, and importance of the issues involved. In addition, Paul Hastings' representation has required it to balance the need to provide quality services with the need to act quickly and represent the Trustee and the Genever Debtors in an effective, efficient, and timely manner. Paul Hastings submits that the hours spent were reasonable given the size and complexity of these chapter 11 cases, the significant, and often urgent, legal and business issues raised, and the numerous pleadings filed in the chapter 11 cases. Furthermore, as noted detailed above, the Trustee and the Genever Debtors also retained NPM as local and conflicts counsel in order to provide services to the Trustee and the Genever Debtors in a costeffective manner. Paul Hastings and NPM have coordinated and will continue to coordinate each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. b. Novelty and Difficulty of the Questions

Paul Hastings tasked knowledgeable attorneys to research, analyze, and advise the Trustee and the Genever Debtors on difficult and complex issues during the Fee Period, including issues related to bankruptcy and litigation. Most notably, as detailed in this Application, Paul Hastings investigated complex estate claims and causes of action in order to recover assets of these estates. c. Skill Requisite to Perform the Legal Services Properly

Paul Hastings believes that its recognized expertise in the areas of financial restructuring and corporate reorganization, its ability to draw from highly experienced professionals in other areas of Paul Hastings' practice, and its creative approach to the resolution of issues has contributed to the effective administration of these chapter 11 cases and benefited the Trustee, the Genever Debtors, their estates, and their unsecured creditors. Due to the nature and complexity of the legal issues presented by these chapter 11 cases, Paul Hastings was required to exhibit a high degree of legal skill in areas related to, among others, bankruptcy and litigation. d. Preclusion of Other Employment by Applicant Due to Acceptance of the Case

Due to the size of Paul Hastings' restructuring and litigation departments, Paul Hastings' representation of the Trustee and the Genever Debtors did not preclude its acceptance of new clients, but the demands for immediate and substantive action in these chapter 11 cases imposed significant burdens on Paul Hastings professionals and paraprofessionals working concurrently on other matters. That said, for the Trustee, his engagement as a chapter 11 trustee has, for all practical purposes precluded other employment given that this matter is taking up most of his time.

Other than the hourly rate for Luc A. Despins (which has been reduced from his standard hourly rate of \$2,225.00 to \$1,975.00), the fees charged by Paul Hastings in these chapter 11 cases are billed in accordance with its existing billing rates and procedures in effect during the Fee Period. The rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. Moreover, when Paul Hastings' restructuring professionals and paraprofessionals work on nonbankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable nonbankruptcy cases in a competitive national legal market. In addition, the firm's customary hourly rates and rate structure reflect that restructuring and related matters typically involve great complexity, numerous tasks requiring a high level of expertise, and severe time pressures, as is the case here. f. Whether the Fee Is Fixed or Contingent

Pursuant to Bankruptcy Code sections 330 and 331, all fees sought by professionals employed under Bankruptcy Code section 1103 are subject to final approval by the Court, and are subject to adjustment depending on the services rendered and the results obtained. Of particular note, payment of Paul Hastings' fees here was contingent in two respects: (1) the recovery of assets for the benefit of the estates and (2) monetizing such assets. At the outset of these chapter 11 cases, there was no assurance whatsoever that assets would be recovered and

monetized to allow for the payment of estate professionals. Accordingly, Paul Hastings' compensation was, in essence, a contingency fee arrangement. The risk that Paul Hastings assumed by representing the Trustee and the Genever Debtors further supports the reasonableness of Paul Hastings' compensation. g. Time Limitations Imposed by the Client or Other Circumstances

During the Fee Period, Paul Hastings was required to analyze and address certain issues arising in these chapter 11 cases under compressed timelines. For example, given the Individual Debtor's track record of moving assets to keep them out of reach of creditors, it was critical that Paul Hastings act quickly on information obtained during the Trustee's investigation in order to freeze assets.

Paul Hastings professionals and paraprofessionals worked diligently to maximize value for these chapter 11 estates. During the Fee Period, and as described in the summary of services herein, Paul Hastings was instrumental in analyzing potential sources of recovery for the benefit of these estates. During the Fee Period, Paul Hastings was able to secure several key rulings from the Court, which rulings will serve as a beachhead for future asset recovery efforts. The reasonableness of Paul Hastings' fees must be evaluated in light of this important strategic factor. i. Experience, Reputation, and Ability of Attorneys

Paul Hastings is consistently recognized as a top tier law firm in the field of business reorganizations and liquidations under chapter 11 of the Bankruptcy Code. During the Application Period, Paul Hastings solicited the skill and expertise of its professionals and paraprofessionals. Paul Hastings professionals have actively represented debtors, creditors, and creditors' committees, as well as other parties in interest, in a number of the nation's largest chapter 11 cases as well as in connection with cross-border restructurings. Paul Hastings' extensive experience enables it to perform the services described herein competently and expeditiously. In addition to its expertise in the area of corporate reorganization, Paul Hastings has called upon the expertise of its attorneys in other practice areas as required during the Fee Period.

As detailed in this Application, the Individual Debtor's in-court and out-of-court tactics illustrate the undesirability of this engagement, which involved harassment of the Trustee and Paul Hastings attorneys (including death threats against the Trustee). As a result, Paul Hastings was forced to incur hundreds of thousands of dollars in cyber security measures (the cost of which are not part of the expenses for which Paul Hastings is seeking reimbursement in this Application). In addition, prior to the Court granting the First Interim Fee Application at the end of June 2023, Paul Hastings was unable to get paid for its fees for almost a year. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 59 of 700

k. Nature and Length of Professional Relationship Paul Hastings has been rendering professional services to (a) the Trustee since its retention as counsel effective as of July 8, 2022, (b) Genever (BVI) since its retention as counsel effective as of October 11, 2022, and (c) Genever (US) since its retention as counsel effective as of November 3, 2022. 122. Paul Hastings respectfully submits that the services for which it seeks

compensation in this Fee Application were, at the time rendered, necessary for and beneficial to the Debtors' estates and their creditors and were rendered to maximize, protect, and preserve value for the Debtors' estates and all parties in interest. Paul Hastings believes that it provided services economically, effectively, and efficiently, and obtained results beneficial to the Debtor's estate and his creditors. Paul Hastings further submit that the compensation requested herein is reasonable in light of the nature, extent, and value of the services rendered during the Fee Period.

123. Paul Hastings also notes that the rates charged during the Fee Period are reasonable. In fact, this Court held that Paul Hastings' New York rates are reasonable because Paul Hastings was retained at New York rates and these cases are extraordinary within this District. See Order Denying Motion for Stay Pending Appeal [Docket No. 1791].

124. All fees incurred by Paul Hastings during the Fee Period were actual, reasonable, and necessary in the performance of services for the Trustee and the Genever Debtors. Paul Hastings respectfully requests approval of the compensation sought herein.

125. As set forth in Exhibit C hereto, Paul Hastings incurred and disbursed \$165,738.27 as expenses in providing professional services during the Fee Period. These expenses include approximately \$66,684.31 for online legal research (i.e., LEXIS and Westlaw). Because Paul Hastings believes that online legal research (e.g., LEXIS and Westlaw) is far more cost-efficient than manual research using hard-bound volumes, Paul Hastings encourages computerized legal research even though it is not a profit center for Paul Hastings. To be clear, Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 60 of 700

Paul Hastings does not charge a mark-up on the LEXIS and Westlaw charges, but merely passes on the costs of such third-party services. Moreover, as it relates to outside professional services, mailing, and other service-related expenses, the Trustee and Paul Hastings are merely passing on the costs of such third-party services, without any mark-up.30

- 126. Additional necessary expenses included: - \$76,061.80 for certain outside professional services, such as document review services by UnitedLex (\$31,080.48) and translation services by Divergent Language Solutions (\$330.00); - \$1,567.12 for document reproductions, namely \$1,245.92 for b/w reproductions (at 8 cents per page) and \$321.20 for color reproductions (at 20 cents per page); - \$809.00 for process servers (e.g., Metro Attorney Service Inc.) to serve, among other things, the subpoenas issued pursuant to the Rule 2004 orders entered by this Court; - \$717.50 for court reporting services; - \$8,332.16 for UPS/courier service, including service of pleadings required to be served in hard copy format; and - \$85.00 for corporate document retrieval services (including United Corporate Service and Corp2000) with respect to various Kwok-related entities. - 127. During the Fee Period, Paul Hastings utilized UnitedLex -- a third party vendor

that specializes in discovery services including document processing, storage, review services, and distribution -- to conduct document review of the documents produced in the chapter 11 cases, including the hundreds of thousands of discovery documents received by the Trustee to date in connection with his investigation.

128. Using their own contract attorneys and review team managers, UnitedLex

provides an efficient and economic means of reviewing large document sets at hourly rates

30 Documentation of these expenses will be made available to the Court upon request. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 61 of 700

significantly lower than Paul Hastings. UnitedLex's document review team charges hourly rates ranging from \$40 to \$55 (for non-management roles) and \$150 (for management role), which is substantially less than Paul Hastings' hourly rates and, moreover, is even less than the hourly rates of associates of local Connecticut counsel (i.e., NPM), whose hourly rates range from \$220 to \$425. For all these reasons, Paul Hastings believes that utilizing the UnitedLex document review team greatly benefits these estates by reducing document review costs. The Trustee also previewed Paul Hastings' use of UnitedLex with the U.S. Trustee, who had no objection thereto (without the Trustee having to file a separate retention application for UnitedLex). The Trustee and Paul Hastings also disclosed in the Fourth Supplemental Declaration of Disinterestedness of Luc A. Despins [Docket No. 1435] that Paul Hastings would utilize UnitedLex's contract attorney services.

129. The time constraints imposed by the circumstances of the matters handled by Paul Hastings during the Fee Period required its attorneys and other employees, at times, to devote substantial time during the evenings and on weekends to perform legal services on behalf of the Trustee. These extraordinary services were essential to meet deadlines, timely respond to inquiries on a daily basis, and satisfy the Trustee's needs and demands. Attorneys and other Paul Hastings employees who worked late in the evenings or on weekends were reimbursed for their reasonable meal and transportation costs in accordance with firm policy. Paul Hastings' regular practice is not to include components for those charges in overhead when establishing billing rates, but rather to charge its clients for these and all other out-of-pocket disbursements incurred during the regular course of the provision of legal services. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 62 of 700

130. In accordance with Appendix D (Guidelines for Compensation and Expense Reimbursement of Professionals) to the Local Rules, reproduction charges have been capped at 20 cents per page.31

131. The expenses requested herein are customarily charged to non-bankruptcy clients of Paul Hastings. Additionally, the expenses incurred by Paul Hastings to third parties are limited to the actual amounts billed to, or paid by, Paul Hastings on behalf of the estates.

132. Paul Hastings believes the rates for charges incurred are the market rates that the majority of law firms charge clients for such services. In addition, Paul Hastings believes that such charges are in accordance with the American Bar Association's ("ABA") guidelines, as set forth in the ABA's Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other charges.

133. The expenses incurred in providing professional services in the Chapter 11 Case were necessary, economical, and justified under the circumstances.

134. Paul Hastings responds to the questions set forth in Paragraph C.5. of the U.S. Trustee Guidelines as follows:

Question: Did you agree to any variations from, or alternatives to, your standard or customary billing rates, fees, or terms for services pertaining to this engagement that were provided during the Fee Period?

Response: Yes. As a courtesy to these estates and based on circumstances unique to these chapter 11 cases, during the Fee Period, Paul Hastings agreed to voluntary fee reductions aggregating \$251,492.22, including the following:

31 Generally, Paul Hastings charges 8 cents per page for black-and-white reproductions and 50 cents per page for color reproductions. In accordance with Appendix D to the Local Rules, Paul Hastings has reduced the charge for color reproductions to 20 cents per page.

(i) Paul Hastings is not seeking allowance or payment at this time of the fees incurred by six (6) timekeepers who billed less than five (5) hours during the Fee Period. The total amount of such fees is \$14,116.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

(ii) As a result of the agreed-upon reduction in Luc A. Despins' hourly rate (from his standard hourly rate of \$2,225 to the reduced hourly rate of \$1,975), an additional \$70,887.50 in fees have been waived. (iii) Paul Hastings voluntarily waived \$166,488.72 in fees related to document review. Question: If the fees sought in this application as compared to the fees budgeted for the Fee Period are higher by 10% or more, did you discuss the reasons for the variation with the client. Response: Not applicable. Question: Have any of the professionals included in this application varied their hourly rate based on the geographic location of the bankruptcy case? Response: No. Question: Does the application include time or fees related to reviewing or revising time records or preparing, reviewing, or revising invoices? (This is limited to work involved in preparing and editing billing records that would not be compensable outside of bankruptcy and does not include reasonable fees for preparing a fee application.) If so, please quantify by hours and fees. Response: The Application does not include time for preparing, reviewing, or revising time records. However, the Application does include approximately 21.4 hours and associated fees of approximately \$38,477.00 related to preparing, reviewing, and revising Paul Hastings' fee statements and ensuring time entries are properly categorized by matter number and task code. On average, approximately 4.3 hours were spent on

each of the five monthly fee statements prepared during the Fee Period.

Question: Does this application include time or fees for reviewing time records to redact any privileged or other confidential information? If so, please quantify by hours and fees.

Response: No.

Question: If the application includes any rate increases since retention: (i) Did your client review and approve those rate increases in advance? (ii) Did your client agree when retaining the law firm to accept all future rates increases? If not, did you inform your client that they need not agree to modified rates or terms in order to have you continue the representation consistent with ABA Formal Ethics Opinion 11-458?

Response: As is customary, Paul Hastings adjusts its hourly rates periodically based upon (i) the advancing seniority of its professionals and paraprofessionals, (ii) the current market for legal services, (iii) the rates charged for comparable non‐ bankruptcy services, and (iv) the firm's analysis of the hourly rates being charged by professionals in other law firms. Effective January 1, 2023, September 1, 2023, and January 1, 2024, Paul Hastings adjusted its hourly rates consistent with the Retention Order [Docket Nos. 668 and 1376] and the Notices of Change in Hourly Rates of Paul Hastings LLP, Counsel to Chapter 11 Trustee [Docket Nos. 1251, 2075, and 2450].

135. To the extent that time or disbursement charges for services rendered or expenses incurred during the Fee Period are not included in this Application, or the Trustee and Paul Hastings have for any reason not sought compensation or reimbursement with respect to such services (including, as noted above, services related to the preparation and prosecution of the Civil RICO Adversary Proceeding), Paul Hastings reserves the right to request compensation and reimbursement for such services in a supplemental or future application in the Debtors' chapter 11 cases. Also, Paul Hastings 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.

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

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WHEREFORE, Paul Hastings respectfully requests entry of an order, substantially in the form attached hereto as Exhibit G, (i) allowing interim compensation for professional services rendered during the Fee Period in the amount of \$5,053,513.53 and reimbursement of \$165,378.27 in expenses, (ii) authorizing payment from the Debtors' estates of 80% of such compensation and 100% of such expenses as it relates to the Fee Period services, (iii) allowing such compensation and payment for professional services rendered and reimbursement of actual and necessary expenses incurred without prejudice to the Trustee's and Paul Hastings' right to seek further compensation and/or payment from the Debtors' estates for the full value of services performed and expenses incurred, and (iv) granting the Trustee and Paul Hastings such other and further relief as is just.

Dated: October 15, 2024 New Haven, Connecticut

> By: /s/ G. Alexander Bongartz G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com

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

Counsel for the Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

-------------------------------------------------------- x

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

-------------------------------------------------------- x

The undersigned hereby certifies that on the date hereof, the foregoing Application was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case 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.1 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.

Dated: October 15, 2024 New Haven, Connecticut

By: /s/ G. Alexander Bongartz G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com

Counsel for the Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC

1 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.

Customary and Comparable Compensation Disclosures

The blended hourly rate for Paul Hastings' timekeepers in its New York and Washington, D.C. offices who billed to non-bankruptcy matters (collectively, the "Non-Bankruptcy Matters")1 during the twelve-month period beginning on August 1, 2023 and ending on July 31, 2024 was, in the aggregate, approximately \$1,234 per hour. The blended hourly rate for Paul Hastings' timekeepers who billed to these chapter 11 cases during the Fee Period was approximately \$1,261 per hour. A detailed comparison of these rates follows:

Category of Timekeeper Blended Hourly Rate

Blended Hourly Rate Debtor Blended Hourly

All Timekeepers Aggregated \$1,234 \$1,261

1 It is the nature of Paul Hastings' practice that certain non-bankruptcy engagements require the advice and counsel of professionals and paraprofessionals who work primarily within Paul Hastings' restructuring group. Accordingly, Non-Bankruptcy Matters consist of matters for which Paul Hastings' timekeepers represented a client in matters other than court-approved engagements as counsel for the debtor, the chapter 11 trustee, or an official committee under the Bankruptcy Code. As such, the Non-Bankruptcy Matters include, in part, time billed by Paul Hastings' timekeepers who work primarily within Paul Hastings' restructuring group.

2 Luc A. Despins brings to the Title III Cases over 36 years of experience representing debtors and creditors in high profile and complex restructuring matters. Given the complexity and challenges faced by the Trustee in these cases, a significant amount of time by senior partners, of counsel, and senior associates, including Mr. Despins, Nicholas Bassett, Alexander Bongartz, Shlomo Maza, and Douglass Barron has been necessary. Because their rates are at the higher end of the range of rates billed by Paul Hastings partners, of counsel, and associates, respectively, and in light of the fact that a significant amount of senior partner, of counsel, and senior associate time has been required for this engagement, the blended rate for this case moved to the higher end of the range of rates billed by Paul Hastings. Finally, the blended attorney hourly rate for the Fee Period is not comparable to the average hourly rate in other matters because it does not reflect numerous cost-saving measures, including the delegation of a variety of matters to NPM, matters for which otherwise more junior Paul Hastings attorneys with lower hourly rates would have been used, thereby reducing Paul Hastings' blended hourly rate.

Summary of Timekeepers Included in this Application

Axelrod, Peter, Litigation, 1997 \$1,775.00 6.90 \$12,247.50 N/A Bassett, Nicholas Corporate, 2007 \$1,835.00 427.30 \$784,095.50 3 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$917.50 6.00 \$5,505.00 3 Despins, Luc Restructuring, 1986 \$1,975.00 281.40 \$555,765.00 1 Despins, Luc (travel; ½ rate) Restructuring, 1986 \$987.50 4.30 \$4,246.25 1

Bongartz, Alex Restructuring, 2007 \$1,850.00 274.90 \$508,565.00 3 Bongartz, Alex (travel, ½ rate) Restructuring, 2007 \$925.00 4.80 \$4,440.00 3 Maza, Shlomo3 Corporate, 2012 \$1,850.00 74.10 \$137,085.00 3 Traxler, Katherine Restructuring, 1990 \$1,120.00 8.30 \$9,296.00 3

Barron, Douglass Corporate, 2012 \$1,395.00 546.60 \$762,507.00 3

½ rate) Corporate, 2012 \$697.50 0.80 \$558.00 3 Catalano, Kristin Corporate, 2021 \$1,185.00 102.90 \$121,936.50 3

½ rate) Corporate, 2021 \$592.50 10.60 \$6,280.50 3 Daly, Crispin Restructuring, 2010 \$1,395.00 37.70 \$52,591.50 3 Farmer, Will Corporate, 2018 \$1,390.00 80.00 \$111,200.00 3 Kim, Sarah Litigation, 2023 \$985.00 157.70 \$155,334.50 N/A Kosciewicz, Jon Litigation, 2021 \$1,185.00 292.80 \$346,968.00 3 Maza, Shlomo3 Corporate, 2012 \$1,395.00 74.20 \$103,509.00 3 Sadler, Tess Corporate, 2019 \$1,365.00 25.50 \$34,807.50 3 Selva, Gianmarco Corporate \$565.00 33.50 \$18,927.50 N/A Song, Luyi Corporate, 2023 \$985.00 642.30 \$632,665.50 3 Song, Luyi (travel; ½ rate) Corporate, 2023 \$492.50 31.60 \$15,563.00 3 Sutton, Ezra Corporate, 2021 \$1,270.00 474.70 \$602,869.00 3 Sylvia, Daniel Corporate, 2021 \$1,270.00 5.30 \$6,731.00 N/A Yu, Annie Corporate, 2024 \$885.00 8.50 \$7,522.50 N/A Associate Total: 2,524.70 \$2,979,971.00

Doherty, Allison Paralegal \$445.00 15.60 \$6,942.00 N/A Kuo, Jocelyn Paralegal \$565.00 32.10 \$18,136.50 1 Laskowski, Mat Paralegal \$565.00 14.40 \$8,136.00 2

Mohamed, David Paralegal \$565.00 315.10 \$178,031.50 2 Vitti, Johnna Paralegal \$485.00 6.80 \$3,298.00 N/A

3 Shlomo Maza was promoted to Of Counsel effective July 1, 2024. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 70 of 700

Paraprofessional Total: 394.10 \$218,786.00

Voluntary fee reduction related to document review: (\$166,488.72)

Summary of Timekeepers Not Included in this Application4

Name Department; Date of First Admission Hourly

Dhamee, Yousuf Investment Funds and Private Capital, 2001 \$1,985.00 1.80 \$3,573.00 Tsao, Leo Litigation, 1999 \$1,775.00 4.20 \$7,455.00

Young, Dominik Corporate, 2023 \$885.00 0.80 \$708.00

Chang, Irene Legal Research Analyst \$420.00 0.40 \$168.00 Gore, Ian Paralegal \$360.00 0.20 \$72.00 Price, Oscar Senior Application Engineer \$535.00 4.00 \$2,140.00 Paraprofessional Total: 4.60 \$2,380.00

4 As noted, as an accommodation to these estates, Paul Hastings is not seeking allowance or payment at this time for the fees of timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$14,116.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses. Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 72 of 700

Summary of Compensation by Project Category

U.S. Trustee Task Code and Project Category Hours

B110 Case Administration 147.70 \$147,229.00 B112 General Creditor Inquiries 0.10 \$185.00 B113 Pleadings Review 176.30 \$100,277.00 B120 Asset Analysis and Recovery 0.20 \$370.00 B130 Asset Disposition 14.70 \$18,183.00 B131 Sale of Real Estate 2.70 \$5,270.00 B155 Court Hearings 169.10 \$207,881.50 B160 Employment / Fee Applications (Paul Hastings) 58.00 \$92,774.00 B165 Employment / Fee Applications (Other Professionals) 36.00 \$58,950.50 B191 General Litigation 2097.80 \$2,921,608.51 B195 Non-Working Travel 58.10 \$36,592.75 B210 Business Operations 154.10 \$213,669.50 B211 Financial Reports (Monthly Operating Reports) 13.00 \$16,919.50 B230 Financing/Cash Collections 22.70 \$39,093.50

B261 Investigations 1042.60 \$1,339,800.99 B310 Claims Administration and Objections 0.40 \$602.00

Voluntary fee reduction related to document review (\$166,488.72)

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 73 of 700

ID Matter Name April 2024 May 2024 June 2024 July 2024 Total Fees

Trustee Representation \$122,544.00 \$110,035.00 \$122,820.00 \$111,983.25 \$467,382.25

Litigation \$565,093.50 \$495,115.00 \$289,208.50 \$277,193.50 \$1,626,610.50 00003 Other Litigation \$98,145.50 \$177,138.25 \$185,936.00 \$75,332.75 \$536,552.50 00004 Corporate Law Issues \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00005 Sale Process \$0.00 \$2,765.00 \$0.00 \$0.00 \$2,765.00 00006 Tax Issues \$13,380.50 \$4,440.00 \$1,480.00 \$1,295.00 \$20,595.50 00007 Foreign Law Issues \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00008 Plan Process Issues \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00010 Genever US \$116,231.50 \$65,248.50 \$46,479.50 \$20,404.00 \$248,363.50 00011 Genever BVI \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00012 Mahwah Adversary \$0.00 \$1,777.00 \$0.00 \$22,356.00 \$24,133.00

Adversary \$28,867.50 \$0.00 \$0.00 \$10,666.50 \$39,534.00 00014 HCHK Adversary \$34,106.50 \$62,196.00 \$160,566.00 \$105,299.50 \$362,168.00 00015 Interpleader Adversary \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00016 Mei Guo Adversary \$790.00 \$6,627.50 \$0.00 \$0.00 \$7,417.50 00017 HK USA Adversary \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00018 Bravo Luck Adversary \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00019 SN Apartment Adversary \$0.00 \$0.00 \$0.00 \$0.00 \$0.00

Adversary \$0.00 \$0.00 \$0.00 \$119,868.00 \$119,868.00 00022 PAX Adversary \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00024 Lamp Capital Adversary \$45,650.00 \$28,258.50 \$20,923.00 \$66,650.00 \$161,481.50 00026 Ace Decade Adversary \$26,323.50 \$44,973.50 \$29,446.00 \$172,731.50 \$273,474.50 00027 Defeng Cao Adversary \$21,011.50 \$52,833.00 \$0.00 \$0.00 \$73,844.50

Adversary \$12,633.50 \$6,682.00 \$17,801.50 \$1,016.00 \$38,133.00 00029 Avoidance Actions \$117,852.46 \$189,111.00 \$197,838.50 \$330,375.00 \$835,176.96 00030 Mediation \$20,591.04 \$133,303.50 \$118,467.00 \$24,225.00 \$296,586.54 00031 Forfeiture Issues \$0.00 \$0.00 \$0.00 \$60,149.00 \$60,149.00 00032 K. Legacy \$0.00 \$0.00 \$5,550.00 \$14,111.50 \$19,661.50 00033 Swiss Proceedings \$0.00 \$0.00 \$4,810.00 \$1,295.00 \$6,105.00 TOTAL \$1,223,221.00 \$1,380,503.75 \$1,201,326.00 \$1,414,951.50 \$5,220,002.25

document review (\$0.00) (\$98,806.22) (\$59,707.50) (\$7,975.00) (\$166,488.72) NET TOTAL \$1,223,221.00 \$1,281,697.53 \$1,141,618.50 \$1,406,976.50 \$5,053,513.53 Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 74 of 700

Expense Category April 2024 May 2024 June 2024 July 2024 Total

Airfare \$1,864.41 \$409.10 \$0.00 \$726.95 \$3,000.46

Documents):

Metro Attorney Service \$269.50 \$539.50 \$0.00 \$0.00 \$809.00

Ancillary Legal Corporation \$0.00 \$10,353.00 \$23,257.00 \$0.00 \$33,610.00 Computer Search (Other) \$0.00 \$867.06 \$540.18 \$741.60 \$2,148.84 Court Reporting Services (Transcripts) \$0.00 \$717.50 \$0.00 \$0.00 \$717.50 Data Base Storage \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 Filing Fee \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 Lexis/On Line Search \$924.30 \$404.51 \$606.17 \$308.75 \$2,243.73 Local - Meals \$40.01 \$116.01 \$169.53 \$350.88 \$676.43 Local - Parking \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 Local - Taxi \$0.00 \$0.00 \$19.15 \$0.00 \$19.15 Lodging \$452.16 \$0.00 \$0.00 \$0.00 \$452.16 Messenger \$0.00 \$446.00 \$0.00 \$0.00 \$446.00 Outside Professional Services:

Divergent Language Solutions, LLC \$0.00 \$0.00 \$0.00 \$330.00 \$330.00

Montvale Moving Services, LLC \$6,065.00 \$0.00 \$0.00 \$0.00 \$6,065.00

PCL4, LLC \$0.00 \$4,976.32 \$0.00 \$0.00 \$4,976.32

UnitedLex 0.00 \$31,080.48 \$0.00 \$0.00 \$31,080.48

Miller Advertising Agency, Inc. \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 Postage/Express Mail \$196.50 \$252.11 \$862.73 \$205.16 \$1,516.50 Reproduction Charges \$109.20 \$94.96 \$884.96 \$156.80 \$1,245.92 Reproduction Charges (Color) \$321.20 \$0.00 \$0.00 \$0.00 \$321.20 Retrieval of Corporate Documents:

TransUnion Risk \$80.00 \$0.00 \$5.00 \$0.00 \$85.00

Other \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 Search Fees \$46.03 \$3.21 \$0.00 \$211.28 \$260.52 Taxi/Ground Transportation \$1,335.77 \$281.17 \$0.00 \$864.98 \$2,481.92 Travel Expense - Meals \$176.36 \$0.00 \$0.00 \$36.23 \$212.59 Travel Expense - Parking \$14.00 \$10.00 \$0.00 \$14.00 \$38.00 UPS/Courier Service \$7,621.98 \$484.35 \$21.05 \$204.78 \$8,332.16 Vendor Expense \$0.00 \$222.30 \$0.00 \$6.51 \$228.81 Westlaw \$45,054.00 \$5,554.58 \$4,393.10 \$9,438.90 \$64,440.58 TOTAL \$64,570.42 \$56,812.16 \$30,758.87 \$13,596.82 \$165,738.27

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 September 12, 2024 Please Refer to Invoice Number: 2403067

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$122,544.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 September 12, 2024 Please Refer to Invoice Number: 2403067

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$122,544.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 78 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 September 12, 2024 Please Refer to Invoice Number: 2403067

FOR PROFESSIONAL SERVICES RENDERED for the period ending April 30, 2024 General Chapter 11 Trustee Representation \$122,544.00

Date Initials Description Hours Rate Amount

04/01/2024 AB21 Update list of open issues and next steps 0.30 1,850.00 555.00 04/01/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/02/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/02/2024 DEB4 Conference with W. Farmer, E. Sutton and L.

and related issues/task list 0.90 1,395.00 1,255.50 04/02/2024 ECS1 Meeting with D. Barron, W. Farmer and L.

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 79 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2403067

Date Initials Description Hours Rate Amount

04/02/2024 LS26 Meeting with D. Barron, E. Sutton and W. Farmer re case issues/task list (0.9); review

04/02/2024 NAB Correspond with A. Luft regarding case

strategy meeting (.3) 0.60 1,835.00 1,101.00 04/02/2024 WCF Conference with L. Song, E. Sutton, D.

04/03/2024 AB21 Call with L. Despins, N. Bassett, A. Luft, D.

regarding case update, strategy, and next

04/03/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/03/2024 DEB4 Conference with L. Despins, N. Bassett, A. Bongartz, S. Maza, W. Farmer, K. Catalano, J. Kosciewicz, E. Sutton regarding pending and upcoming case matters 1.80 1,395.00 2,511.00 04/03/2024 ECS1 Meeting with L. Despins, N. Bassett, A. Bongartz, A. Luft, D. Barron, S. Maza, W.

(1.8); revise agenda for same (.4); review certain issues and documents to prepare for

and L. Song regarding same (.1) 2.60 1,270.00 3,302.00 04/03/2024 JPK1 Attend meeting with L. Despins, N. Bassett, A. Bongartz, A. Luft, D. Barron, S. Maza,

regarding open issues, case plan, and next

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 80 of 700

Date Initials Description Hours Rate Amount

04/03/2024 KC27 Attend meeting with L. Despins, N. Bassett, A. Bongartz, A. Luft, D. Barron, S. Maza,

open issues, discovery, case plan 1.80 1,185.00 2,133.00 04/03/2024 LAD4 All hands call with N. Bassett, A. Luft, D. Barron, A. Bongartz, S. Maza, E. Sutton re: next steps and strategy 1.80 1,975.00 3,555.00 04/03/2024 NAB Review and supplement agenda for case update and strategy meeting (.3); participate in same with L. Despins, A. Bongartz, A. Luft, D. Barron, S. Maza, W. Farmer, K. Catalano, J. Kosciewicz, and E. Sutton (1.8) 2.10 1,835.00 3,853.50 04/03/2024 SM29 Participate in portion of meeting with L. Despins, N. Bassett, A. Bongartz, A. Luft, D. Barron, W. Farmer, K. Catalano, J. Kosciewicz, and E. Sutton re case update, strategy, and next steps 1.40 1,395.00 1,953.00 04/03/2024 WCF Participate in portion of conference with L. Despins, N. Bassett, A. Bongartz, A. Luft, D. Barron, S. Maza, K. Catalano, J.

04/04/2024 AB21 Update list of open issues and workstreams 0.10 1,850.00 185.00 04/04/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/05/2024 DM26 Update critical dates calendar & send

filing deadlines and update working group re same (.2); review and revise motions to

case and adversary proceedings (1.6) 2.30 565.00 1,299.50 04/05/2024 ECS1 Correspond with J. Kuo and D. Mohamed regarding motions to withdraw for A. Luft in adversary proceedings and district court

regarding same (.1) 0.30 1,270.00 381.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 81 of 700

Date Initials Description Hours Rate Amount

04/05/2024 JK21 Correspond with P. Linsey (NPM)

withdraw appearance (0.1); electronically file

appearance of A. Luft (1.7) 1.80 565.00 1,017.00 04/05/2024 LAD4 T/c N. Bassett & A. Luft re: download before A. Luft departure 0.30 1,975.00 592.50 04/05/2024 NAB Call with A. Luft regarding case issues,

(.4); follow up call with A. Luft and L.

related to same (.1) 0.80 1,835.00 1,468.00 04/08/2024 AB21 Update list of open issues and workstreams 0.30 1,850.00 555.00 04/08/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/08/2024 DEB4 Correspond with L. Despins and N. Bassett regarding NPM matters 0.10 1,395.00 139.50 04/08/2024 NAB Telephone conference with P. Linsey

issues and strategy 0.60 1,835.00 1,101.00 04/09/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/09/2024 JK21 Correspond with D. Mohamed regarding

04/10/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/11/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

Date Initials Description Hours Rate Amount

04/11/2024 NAB Correspond with L. Despins regarding case

04/12/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/15/2024 AB21 Update list of open issues and workstreams 0.10 1,850.00 185.00 04/15/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/15/2024 NAB Correspond with P. Linsey (NPM) regarding case strategy, case developments, and avoidance action issues 0.30 1,835.00 550.50 04/16/2024 AB21 Update list of open issues and workstreams 0.20 1,850.00 370.00 04/16/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/16/2024 DEB4 Conference with L. Despins, N. Bassett, L. Song, P. Linsey regarding NPM matters 1.00 1,395.00 1,395.00 04/16/2024 DEB4 Conferences with P. Linsey (NPM) regarding NPM matters 0.30 1,395.00 418.50 04/17/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/17/2024 NAB Correspond with L. Despins regarding case management issues 0.30 1,835.00 550.50 04/18/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/19/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group 0.80 565.00 452.00

Date Initials Description Hours Rate Amount

04/21/2024 AB21 Update list of open issues and workstreams 0.30 1,850.00 555.00 04/21/2024 NAB Correspond with L. Despins regarding case management and data protection issues 0.20 1,835.00 367.00 04/22/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/22/2024 LAD4 T/c S. Sarnoff (OMM) re: update on

04/23/2024 AB21 Update list of open issues and workstreams 0.20 1,850.00 370.00 04/23/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/24/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/25/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

04/26/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group re same (.2); draft certificate of service

(.4); correspond with A. Bongartz re same

04/29/2024 AB21 Update list of open issues and workstreams 0.10 1,850.00 185.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 84 of 700 Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2403067

Date Initials Description Hours Rate Amount

04/29/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

filing deadlines and update working group

04/30/2024 DEB4 Correspond with T. Sadler regarding UST

04/01/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review related case dockets regarding recent filings (.8) 1.80 565.00 1,017.00

04/02/2024 DM26 Review recent filings in Kwok case no. 22-

(.4); review related case dockets regarding recent filings (.6) 1.40 565.00 791.00 04/03/2024 DM26 Review recent filings in Kwok case no. 22-

(.6); review related case dockets regarding recent filings (.7) 1.80 565.00 1,017.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 85 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2403067

Date Initials Description Hours Rate Amount

04/04/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review related case dockets regarding recent filings (.7) 1.80 565.00 1,017.00 04/05/2024 DM26 Review recent filings in Kwok case no. 22-

(1.3); review related case dockets re:

filings (.6); research certain case documents per attorney request (.4) 2.70 565.00 1,525.50 04/08/2024 DM26 Review recent filings in Kwok case no. 22-

(1.1); review related case dockets regarding recent filings (.5) 2.10 565.00 1,186.50 04/09/2024 DM26 Review recent filings in Kwok case no. 22-

(.8); review related case dockets regarding recent filings (.6) 1.80 565.00 1,017.00 04/10/2024 DM26 Review recent filings in Kwok case no. 22-

(1.2); review related case dockets regarding recent filings (.6); research certain case documents per attorney request (.3) 2.50 565.00 1,412.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 86 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2403067

Date Initials Description Hours Rate Amount

04/11/2024 DM26 Review recent filings in Kwok case no. 22-

(.4); review related case dockets regarding

access/review (.4) 2.10 565.00 1,186.50 04/12/2024 DM26 Review recent filings in Kwok case no. 22-

(.9); review related case dockets regarding recent filings (.5) 2.60 565.00 1,469.00 04/15/2024 DM26 Review recent filings in Kwok case no. 22-

(.3); review related case dockets regarding recent filings (.5); research case documents per attorney request (.4) 1.70 565.00 960.50 04/16/2024 DM26 Review recent filings in Kwok case no. 22-

(.3); review related case dockets regarding recent filings (.6); prepare certain case documents for attorney review (.3) 1.60 565.00 904.00 04/17/2024 DM26 Review recent filings in Kwok case no. 22-

(.9); review related case dockets regarding recent filings (.6) 2.00 565.00 1,130.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 87 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2403067

Date Initials Description Hours Rate Amount

04/18/2024 DM26 Review recent filings in Kwok case no. 22-

(.7); review related case dockets regarding recent filings (.6); prepare certain case documents for attorney review (.4) 2.10 565.00 1,186.50 04/19/2024 DM26 Review recent filings in Kwok case no. 22-

(.8); review related case dockets regarding recent filings (.6) 1.90 565.00 1,073.50 04/22/2024 DM26 Review recent filings in Kwok case no. 22-

(.7); review related case dockets regarding recent filings (.6); research case documents per attorney request (.5) 2.50 565.00 1,412.50 04/23/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review related case dockets regarding recent filings (.7) 1.90 565.00 1,073.50 04/24/2024 DM26 Review recent filings in Kwok case no. 22-

(.7); review related case dockets re: recent filings (.6); research case documents per attorney request (.3) 2.20 565.00 1,243.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 88 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2403067

Date Initials Description Hours Rate Amount

04/25/2024 DM26 Review recent filings in Kwok case no. 22-

(.2); review related case dockets regarding recent filings (.7); research case documents per attorney request (.4) 2.10 565.00 1,186.50 04/26/2024 DM26 Review recent filings in Kwok case no.

(.4); review related case dockets regarding recent filings (.6); research case documents per attorney request (.3) 2.00 565.00 1,130.00 04/29/2024 DM26 Review recent filings in Kwok case no. 22-

(.7); review related case dockets regarding recent filings (.6) 1.70 565.00 960.50 04/30/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review related case dockets regarding recent filings (.6); research certain case documents per attorney request (.4) 2.00 565.00 1,130.00 Subtotal:

04/18/2024 DM26 Prepare agenda for 4/23/24 hearing 0.90 565.00 508.50

Subtotal: B155 Court Hearings 0.90 508.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 89 of 700

Initials Description Hours Rate Amount

04/03/2024 ECS1 Review D. Barron correspondence regarding potential new parties in interest 0.10 1,270.00 127.00 04/04/2024 AB21 Call with D. Barron regarding PH January fee statement (0.1); correspond with A. Luft regarding same (0.1); revise same (0.1) 0.30 1,850.00 555.00 04/04/2024 DEB4 Call with A. Bongartz regarding January fee

04/09/2024 AB21 Correspond with N. Bassett regarding new additional matters for Kwok case 0.10 1,850.00 185.00 04/09/2024 AB21 Review PH February fee statement 0.50 1,850.00 925.00 04/10/2024 AB21 Review PH January 2024 fee statement

statements (0.2) 1.30 1,850.00 2,405.00 04/11/2024 AB21 Revise PH February fee statement 0.80 1,850.00 1,480.00 04/12/2024 AB21 Correspond with C. Edge regarding PH February fee statement 0.10 1,850.00 185.00 04/17/2024 AB21 Review research results from PH Conflicts

disinterestedness 0.30 1,850.00 555.00 04/18/2024 AB21 Correspond with L. Despins regarding next

disinterestedness (0.5); call with E. Sutton regarding same (0.1) 0.60 1,850.00 1,110.00 04/18/2024 ECS1 Call with A. Bongartz regarding disclosures for Trustee's supplemental declaration of disinterestedness (.1); analyze same (.2); correspond with J. Kuo regarding same (.2) 0.50 1,270.00 635.00 04/18/2024 ECS1 Review list of additional interested parties

Date Initials Description Hours Rate Amount

04/18/2024 JK21 Update parties in interest list for retention

04/19/2024 AB21 Revise PH January fee statement (1.1);

04/19/2024 ECS1 Prepare Trustee's supplemental declaration of disinterestedness 0.20 1,270.00 254.00 04/19/2024 ECS1 Review list of additional interested parties

research related to same (.2); correspond

04/20/2024 AB21 Review PH February fee statement 0.20 1,850.00 370.00 04/21/2024 ECS1 Prepare Trustee's supplemental declaration of disinterestedness (.5); correspond with A. Bongartz regarding same (.1) 0.60 1,270.00 762.00 04/22/2024 AB21 Review PH February fee statement 0.20 1,850.00 370.00 04/23/2024 AB21 Revise PH February fee statement (0.8);

04/25/2024 ECS1 Prepare Trustee's supplemental declaration of disinterestedness (.7); correspond with A. Bongartz regarding same (.1) 0.80 1,270.00 1,016.00 04/25/2024 KAT2 Prepare UST Appendix B information

of fifth interim fee application (.2) 0.40 1,120.00 448.00 04/26/2024 KAT2 Prepare parts of fifth interim fee application 0.40 1,120.00 448.00 04/30/2024 AB21 Revise PH declaration of disinterestedness 0.20 1,850.00 370.00 Subtotal: B160 Fee/Employment Applications 11.50 17,819.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 91 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2403067

Date Initials Description Hours Rate Amount

B165 Fee/Employment Applications for Other Professionals 04/19/2024 AB21 Call with A. Thorp (Harneys Legal), B. Hobden (Harneys Legal), D. Barron, and E. Sutton regarding retention of Harneys Legal as Cayman counsel (0.2); prepare notes for same (0.2); call with E. Sutton regarding Harneys Legal retention application (0.1) 0.50 1,850.00 925.00 04/19/2024 AB21 Correspond with D. Hayek (Prager) regarding fee statement 0.10 1,850.00 185.00 04/19/2024 DEB4 Conference with A. Bongartz, E. Sutton and Cayman counsel regarding retention 0.20 1,395.00 279.00 04/19/2024 ECS1 Prepare addendum to retention application for Harneys as Cayman Island counsel (.2);

regarding same (.1); prepare updated list of interested parties for same (.2); correspond

04/20/2024 ECS1 Continue preparing addendum to retention

interested parties for same (.1) 0.70 1,270.00 889.00 04/21/2024 ECS1 Continue preparing addendum to retention

with A. Bongartz regarding same (.1) 1.60 1,270.00 2,032.00 04/23/2024 AB21 Prepare Prager fee statement and exhibit

04/25/2024 AB21 Finalize Prager fee statement (0.2);

filing of same (0.1); serve fee statement on notice parties (0.1) 0.40 1,850.00 740.00 04/25/2024 AB21 Review Kroll March 2024 fee statement 0.20 1,850.00 370.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 92 of 700

Date Initials Description Hours Rate Amount

04/26/2024 AB21 Correspond with H. Claiborn (U.S. Trustee) regarding Prager fee statement 0.10 185.00 04/29/2024 AB21 Review Kroll March fee statement and related cover notice (0.2); correspond with P. Parizek (Kroll) regarding same (0.1);

04/30/2024 AB21 Revise P. Wright fee application (0.4); correspond with L. Despins regarding same

(Pallas) regarding same (0.1) 0.60 1,850.00

04/30/2024 AB21 Analyze H. Claiborn (U.S. Trustee) email regarding Prager fee statement (0.1); call with K. Traxler regarding same (0.1) 0.20

04/30/2024 KAT2 Call with A. Bongartz regarding Prager fee questions (.1); review and respond to C. Edge inquiries regarding March services (.2) 0.30 1,120.00 336.00 Subtotal: B165 Fee/Employment Applications for

04/23/2024 LAD4 Travel back and forth to Bridgeport for hearing (bill at 1/2 rate) 1.10 987.50 1,086.25 04/23/2024 NAB Travel to and from WDC and Connecticut for hearing (bill at 1/2 rate) 2.50 917.50 2,293.75

04/02/2024 AB21 Call with T. Sadler regarding wire transfer to Pullman 0.10 1,850.00 185.00 04/02/2024 JK21 Correspond with T. Sadler regarding wire transfer forms (0.1); prepare wire transfer form for Pullman (0.1) 0.20 565.00 113.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 93 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2403067

Date Initials Description Hours Rate Amount

04/02/2024 TS21 Correspond with A. Bongartz, J. Kuo and

Pullman & Comley (.2); call with A.

Pullman & Comley wire transfer form (.2) 0.50 1,365.00 682.50 04/03/2024 JK21 Correspond with T. Sadler regarding wire transfer forms (0.1); prepare wire transfer form for Paramount (0.1) 0.20 565.00 113.00 04/03/2024 TS21 Correspond with J. Kuo and L. Despins

wire form to Paramount (.2) 0.50 1,365.00 682.50 04/05/2024 TS21 Correspond with A. Bongartz and D. Barron regarding AIG payment 0.30 1,365.00 409.50 04/11/2024 JK21 Correspond with T. Sadler regarding wire transfer forms (0.1); prepare wire transfer form for Hillmann (0.1) 0.20 565.00 113.00 04/11/2024 TS21 Correspond with J. Kau re wires for Hillman (.1); review same (.2); correspond

04/15/2024 TS21 Correspond with L. Despins and East West bank re wire transfer for Acheson Doyle 0.20 1,365.00 273.00 04/16/2024 TS21 Correspond re UST quarterly fees with L. Despins and D. Barron 0.40 1,365.00 546.00 04/18/2024 AB21 Correspond with N. Bassett regarding trustee bank account 0.10 1,850.00 185.00 04/19/2024 AB21 Analyze open invoices and upcoming wire transfers (0.3); call with P. Linsey (NPM) regarding NPM invoice (0.1) 0.40 1,850.00 740.00 04/26/2024 AB21 Correspond with T. Sadler regarding payment of OMJB fees 0.10 1,850.00 185.00 04/30/2024 TS21 Correspond with D. Barron re UST

Subtotal: B210 Business Operations 4.10 5,456.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 94 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2403067

Date Initials Description Hours Rate Amount

B211 Financial Reports (Monthly Operating Reports) 04/19/2024 DEB4 Correspond with T. Sadler regarding MOR 0.20 1,395.00 279.00 04/19/2024 TS21 Prepare March monthly operating report (1.6); correspond with D. Barron and East West bank re same (.5) 2.10 1,365.00 2,866.50 04/22/2024 DM26 File monthly operating report for period ending 3/31/24 for Kwok debtor 0.20 565.00 113.00

Subtotal: Correspond with D. Barron, L. Despins and

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 2.60 1,975.00 5,135.00 LAD4 Luc A. Despins Partner 1.10 987.50 1,086.25 NAB Nicholas A. Bassett Partner 5.00 1,835.00 9,175.00 NAB Nicholas A. Bassett Partner 2.50 917.50 2,293.75 AB21 Alex Bongartz Of Counsel 14.00 1,850.00 25,900.00 KAT2 Katherine A. Traxler Of Counsel 1.10 1,120.00 1,232.00 DEB4 Douglass E. Barron Associate 4.70 1,395.00 6,556.50 SM29 Shlomo Maza Associate 1.40 1,395.00 1,953.00 WCF Will C. Farmer Associate 2.00 1,390.00 2,780.00 TS21 Tess Sadler Associate 5.20 1,365.00 7,098.00 ECS1 Ezra C. Sutton Associate 11.90 1,270.00 15,113.00 KC27 Kristin Catalano Associate 1.80 1,185.00 2,133.00 JPK1 Jon P. Kosciewicz Associate 1.80 1,185.00 2,133.00

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan

LS26 Luyi Song Associate 1.10 985.00 1,083.50

JK21 Jocelyn Kuo Paralegal 3.30 565.00 1,864.50 DM26 David Mohamed Paralegal 65.50 565.00 37,007.50

Date Description Quantity Rate Amount 04/01/2024 Photocopy Charges 758.00 0.08 60.64 04/16/2024 Photocopy Charges 112.00 0.08 8.96 04/18/2024 Photocopy Charges 35.00 0.08 2.80 04/24/2024 Photocopy Charges 160.00 0.08 12.80 04/24/2024 Photocopy Charges (Color) 1,424.00 0.20 284.80 04/30/2024 Photocopy Charges 80.00 0.08 6.40 03/04/2024 UPS/Courier Service - Federal Express, Invoice# 8-426-83911 Dated 03/04/24, Packages from various persons going to various persons. Carrie, I think we need more info here for the U.S. Trustee. 2,843.43 03/04/2024 UPS/Courier Service - Federal Express, Invoice# 8-426-83912 Dated 03/04/24, FedEx Courier

03/04/2024 UPS/Courier Service - Federal Express, Invoice# 8-426-83912 Dated 03/04/24, FedEx Courier

03/04/2024 UPS/Courier Service - Federal Express, Invoice# 8-426-83912 Dated 03/04/24, FedEx Courier

03/04/2024 UPS/Courier Service - Federal Express, Invoice# 8-426-83912 Dated 03/04/24, FedEx Courier

03/04/2024 UPS/Courier Service - Federal Express, Invoice# 8-426-83912 Dated 03/04/24, FedEx Courier

03/04/2024 UPS/Courier Service - Federal 8-426-83912 Dated 03/04/24, FedEx Courier services provided February 2024 Express, Invoice# 398.42

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 96 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 19

8-426-83912 Dated 03/04/24, FedEx Courier

8-426-83915 Dated 03/04/24, Packages from various persons going to various persons. Carrie, I think we need more info here for the U.S. Trustee. 492.81

2-249-54439 Dated 03/05/24, Packages from various persons going to various persons.

think we may need more info here. 125.50

2-251-70005 Dated 03/12/24, Packages from various persons going to various persons. Carrie, I think we may need more info here. 500.38

8-441-67471 Dated 03/18/24, Packages from various persons going to various persons. 493.71

2-253-91511 Dated 03/19/24, Packages from various persons going to various persons.

8-448-89944 Dated 03/25/24, Packages from various persons going to various persons. Carrie, I think we need more info here for the U.S. Trustee. 167.32

2-256-14498 Dated 03/26/24, Packages from various persons going to various persons.

8-456-03339 Dated 04/01/24, Packages from various persons going to various persons. Return from Thomas J. Rhodes Industrial, Trenton, NJ

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 97 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 20

2-260-47022 Dated 04/09/24, Packages from La office to Seoul office & Federal express-Japan to 274.71

Soyoung Jung.

Nick Bassett; 04/01/2024; From/To: DCA/LGA; Airfare Class: Economy; Travel to New York and Connecticut for Kwok mediation

Nick Bassett; 04/02/2024; Restaurant: Starbucks; City: Washington, DC; Breakfast; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 11.66

Nick Bassett; 04/04/2024; Restaurant: Black Seed Bagels; City: New York; Lunch; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 16.53

Nick Bassett; 04/03/2024; Restaurant: Pita Yeero; City: New York; Lunch; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 20.58

Nick Bassett; 04/02/2024; Restaurant: Mysttik Masaala; City: New York; Lunch; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 25.12

Nick Bassett; 04/04/2024; Restaurant: Dunkin Donuts; City: New York; Breakfast; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 25.55

Nick Bassett; 04/03/2024; Restaurant: Avenue Newsstand; City: New York; beverage; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 3.11

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 98 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 21

Nick Bassett; 04/03/2024; Restaurant: Starbucks; City: New York; breakfast; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 9.29

Nick Bassett; 04/04/2024; Hotel: Hyatt; New York; Check-in date: 04/03/2024; Check-out

Connecticut for Kwok mediation hearing 452.16

Nick Bassett; 04/02/2024; From/To: home/airport; Service Type: Uber; Time: 05:46; Travel to New York and Connecticut for Kwok mediation hearing 27.37

Nick Bassett; 04/04/2024; From/To: restaurant/hotel; Service Type: Uber; Time: 01:02; Travel to New York and Connecticut for Kwok mediation hearing 27.81

Nick Bassett; 04/04/2024; From/To: airport/home; Service Type: Uber; Time: 19:00; Travel to New York and Connecticut for Kwok mediation hearing 33.56

Nick Bassett; 04/03/2024; From/To: restaurant/hotel; Service Type: Uber; Time: 18:22; Travel to New York and Connecticut for Kwok mediation hearing 69.73

Nick Bassett; 04/04/2024; From/To: office/airport; Service Type: Uber; Time: 15:04; Travel to New York and Connecticut for Kwok mediation hearing 88.46

Nick Bassett; 04/02/2024; From/To: airport/PH office; Service Type: Uber; Time: 08:04; Travel to New York and Connecticut for Kwok mediation hearing 89.64

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 99 of 700

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 22

Total Costs incurred and advanced \$13,443.72

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 100 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$566,651.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 101 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$566,651.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 102 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 12, 2024

FOR PROFESSIONAL SERVICES RENDERED for the period ending April 30, 2024 Asset Recovery Investigation and Litigation \$566,651.00

Date Initials Description Hours Rate Amount

04/18/2024 ECS1 Review and revise agenda for 4/23/24

regarding same (.1) 0.20 1,270.00 254.00 04/23/2024 LAD4 Hearing on mediation and HCHK motion

04/23/2024 NAB Paraticipate in hearing on

Subtotal:

04/01/2024 DEB4 Conference with S. Maza regarding open litigation issues 0.30 1,395.00 418.50

04/01/2024 KC27 Analyze precedent re withdrawal of

04/01/2024 LAD4 Handle weekly call with NPM (local) with N. Bassett, A. Luft 0.50 1,975.00 987.50

Date Initials Description Hours Rate Amount

04/01/2024 LS26 Correspond with D. Barron re case and litigation issues/task list 0.80 985.00 788.00 04/01/2024 NAB Call with P. Linsey (NPM) and L. Despins

updates and next steps (.5); analyze legal issues related to same (.9) 1.40 1,835.00 2,569.00

with D. Barron re open litigation issues 0.30 1,395.00 418.50 04/02/2024 DEB4 Correspond with E. Sutton regarding adversary proceeding updates 0.10 1,395.00 139.50 04/02/2024 ECS1 Review United Kingdom case in connection

court judgments internationally (.2);

04/02/2024 JK21 Update appeals tracking chart 0.40 565.00 226.00 04/03/2024 DM26 Research and update spreadsheet regarding returned mail related to service of pleadings 0.50 565.00 282.50 04/03/2024 DEB4 Correspond with A. Luft regarding certain litigation documents (0.5); correspond with

and upcoming litigation issues (1.0) 1.50 1,395.00 2,092.50 04/04/2024 DEB4 Correspond with N. Bassett and L. Despins regarding Churchill Mortgage case law 0.20 1,395.00 279.00 04/05/2024 DM26 Review returned mail related to service of

04/05/2024 DEB4 Correspond with A. Luft regarding litigation

04/07/2024 JPK1 Correspond with D. Barron regarding O'Melveny exhibits 0.10 1,185.00 118.50 04/08/2024 DEB4 Analyze case law on foreign enforcement issues (2.3); conference with L. Song, J.

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 104 of 700

Date Initials Description Hours Rate Amount

04/08/2024 ECS1 Call with D. Barron, J. Kosciewicz and L.

Swiss court discovery 1.00 1,270.00 1,270.00 04/08/2024 LS26 Analyze issue re jurisdiction limit on foreign assets (1.2); meeting with D. Barron, E.

issues/task list (1.0) 2.20 985.00 2,167.00 04/09/2024 DM26 Review returned mail related to service of

04/09/2024 DEB4 Correspond with K. Catalano and L. Song regarding judgment enforcement issues 0.40 1,395.00 558.00 04/09/2024 KC27 Prepare notes from meeting on April 3 re litigation workstreams 0.20 1,185.00 237.00 04/09/2024 WCF Update litigation workstreams summary 0.10 1,390.00 139.00 04/10/2024 DM26 Review and update spreadsheet regarding returned mail related to service of pleadings related to avoidance actions 0.70 565.00 395.50 04/10/2024 DEB4 Prepare parts of complaint to recover additional assets (4.3); correspond with S.

04/10/2024 DEB4 Correspond with L. Despins regarding complaint to recover additional assets (0.1);

judgment enforcement issues (0.4);

04/10/2024 JPK1 Correspond with E. Sutton regarding Swiss unsealing project (.1); correspond with D. Barron regarding the same (.1) 0.20 1,185.00 237.00 04/11/2024 DM26 Review and update spreadsheet regarding returned mail related to service of pleadings 1.50 565.00 847.50 04/11/2024 DEB4 Correspond with L. Song regarding

additional assets (0.3); continue preparing

Date Initials Description Hours Rate Amount

04/11/2024 DEB4 Correspond with W. Farmer regarding asset stipulation (0.1); prepare same (0.4) 0.50 1,395.00 697.50 04/11/2024 KC27 Call with S. Maza and E. Sutton re equitable

and E. Sutton regarding related caselaw (.4) 0.50 1,185.00 592.50 04/11/2024 WCF Review asset stipulation precedents (.4);

04/12/2024 DEB4 Correspond with E. Sutton regarding alter ego orders and stipulations (0.3); correspond with L. Despins and N. Bassett regarding same (0.2); revise consent motion (0.3); correspond with M. Conway regarding consent motion (0.1) 0.90 1,395.00 1,255.50 04/12/2024 LAD4 Review/edit Ducati motorcycle motion 0.90 1,975.00 1,777.50 04/12/2024 NAB Review and revise draft complaint regarding

with D. Barron regarding same (.3) 1.40 1,835.00 2,569.00 04/13/2024 DEB4 Correspond with L. Despins regarding complaint to recover additional assets (0.1); revise and supplement same (2.8) 2.90 1,395.00 4,045.50

complaint related to UK apartment funding 0.40 1,835.00 734.00 04/15/2024 DEB4 Correspond with L. Song regarding complaint to recover additional assets 0.10 1,395.00 139.50 04/15/2024 DEB4 Correspond with N. Bassett regarding complaint to recover additional assets 0.20 1,395.00 279.00 04/15/2024 DEB4 Analyze tolling order 0.30 1,395.00 418.50 04/15/2024 DEB4 Correspond with S. Maza regarding tolling

04/15/2024 ECS1 Prepare insert to complaint re debtor's apartment (.7); correspond with D. Barron regarding same (.1) 0.80 1,270.00 1,016.00 04/16/2024 DEB4 Correspond with M. McFarlane regarding

04/16/2024 DEB4 Correspond with L. Despins regarding

Date Initials Description Hours Rate Amount

04/16/2024 DEB4 Correspond with S. Maza regarding upcoming litigation issues 0.30 1,395.00 418.50 04/16/2024 DEB4 Call with L. Song re Mercantile arbitration

04/16/2024 LAD4 Handle weekly call with NPM with D. Barron, N. Bassett, L. Song 1.00 1,975.00 1,975.00 04/16/2024 LS26 Call with D. Barron re Mercantile

documents re same (0.3) 0.60 985.00 591.00

re Arethusa Forsyth 0.30 985.00 295.50 04/16/2024 NAB Correspond with L. Despins, P. Linsey (NPM) regarding litigation strategy 0.30 1,835.00 550.50 04/16/2024 NAB Telephone conference with L. Despins, P.

regarding case developments and strategy 1.00 1,835.00 1,835.00 04/17/2024 DEB4 Correspond with L. Song regarding certain

04/17/2024 DEB4 Correspond with N. Bassett regarding

04/17/2024 DEB4 Conference with E. Sutton, L. Song, J. Kosciewicz regarding litigation issues and

04/17/2024 ECS1 Call with D. Barron, J. Kosciewicz and L. Song regarding litigation issues/task list 0.90 1,270.00 1,143.00 04/17/2024 JK21 Update appeals tracking chart 0.20 565.00 113.00 04/17/2024 JPK1 Call with D. Barron, L. Song, and E. Sutton regarding pending and upcoming litigation

04/17/2024 LS26 Meeting with D. Barron, E. Sutton, and J. Kosciewicz re litigation workstreams update 0.90 985.00 886.50

complaint to recover additional assets 0.10 1,395.00 139.50 04/18/2024 JK21 Update appeals tracking chart 0.10 565.00 56.50 04/18/2024 NAB Correspond with P. Linsey (NPM) regarding litigation issues (.2); correspond 0.40 1,835.00 734.00

Date Initials Description Hours Rate Amount

04/19/2024 DEB4 Revise and supplement complaint to recover additional assets 1.20 1,395.00 1,674.00 04/21/2024 LS26 Prepare adversary proceeding defendant list 1.30 985.00 1,280.50 04/24/2024 DM26 Prepare chart regarding counsel for Kwok related litigation cases 0.50 565.00 282.50 04/24/2024 DEB4 Analyze SDNY case on alter ego issues (0.4); correspond with L. Despins regarding

regarding same (0.3) 0.80 1,395.00 1,116.00 04/24/2024 LAD4 Review choice of law on veil piercing

04/24/2024 LS26 Prepare list of counsel in Kwok related litigation (0.4); correspond with D. Mohamed re same (0.2) 0.60 985.00 591.00 04/24/2024 NAB Correspond with W. Farmer regarding appellate issues and deadlines 0.10 1,835.00 183.50 04/25/2024 DM26 Review case dockets in Kwok-related litigation and supplement chart regarding

04/25/2024 IC Research service information for A. Forsyth 0.40 420.00 168.00 04/25/2024 KC27 Analyze case law regarding choice of law

04/25/2024 LS26 Conference with N. Bassett and D. Barron

meeting with D. Barron re investigation and litigation issues/task list (1.2) 1.60 985.00 1,576.00 04/28/2024 DEB4 Correspond with K. Catalano regarding

04/28/2024 NAB Correspond with W. Farmer regarding

04/29/2024 DEB4 Conference with P. Linsey (NPM), L. Despins, N. Bassett, and L. Song regarding pending and upcoming case litigation 0.90 1,395.00 1,255.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 108 of 700

Date Initials Description Hours Rate Amount

04/29/2024 KC27 Analyze case law regarding conflict of laws (3.9); summarize findings on same (1.3);

04/29/2024 LS26 Case update call with P. Linsey (NPM), D. Skalka (NPM), L. Despins, N. Bassett, D.

04/29/2024 NAB Call with L. Despins, P. Linsey, D. Skalka

case updates and strategy 0.90 1,835.00 1,651.50 04/30/2024 DEB4 Correspond with L. Despins regarding potential UK avoidance litigation (0.1); analyze documents related to same (0.5) 0.60 1,395.00 837.00 04/30/2024 LS26 Prepare summary chart on tolling

Subtotal: B191 General Litigation 68.20 86,847.01

04/01/2024 DEB4 Correspond with E. Sutton regarding UK discovery list (0.2); analyze case documents

04/01/2024 DEB4 Analyze case documents related to

04/01/2024 ECS1 Analyze issues regarding discovery related to United Kingdom based affiliates of the

description of their role and relevance in connection with same (.1); correspond with D. Barron regarding same (.1) 0.50 1,270.00 635.00 04/01/2024 LS26 Conference with J. Barker (Kroll), P. Parizek (Kroll) and P. Levenson regarding

(0.5); review documents re same (0.3); correspond with P. Parizek re same (0.2); prepare summary regarding potential assets in foreign jurisdiction (1.0) 2.00 985.00 1,970.00

Date Initials Description Hours Rate Amount

04/02/2024 DS50 Review and draft summary of Reverence I

04/02/2024 DEB4 Correspond with L. Despins regarding (0.1); correspond with A. Lomas (Kroll) regarding fund tracing (0.1) 0.20 1,395.00 279.00 04/02/2024 DEB4 Correspond with P. Linsey (NPM) regarding vehicles 0.10 1,395.00 139.50 04/02/2024 DEB4 Conference with P. Linsey regarding Troutman Sanders (0.3); correspond with L. Song regarding UK law issues (0.2) 0.50 1,395.00 697.50 04/02/2024 DEB4 Analyze case documents 2.20 1,395.00 3,069.00 04/02/2024 JPK1 Correspond with E. Sutton regarding remaining Rule 2004 depositions 0.10 1,185.00 118.50 04/02/2024 YID Review Fund documents with focus on liquidation of portfolio 0.70 1,985.00 1,389.50 04/03/2024 AB21 Review summary judgment decision in Bombardier adversary proceeding 0.30 1,850.00 555.00 04/03/2024 DEB4 Analyze discovery documents 2.50 1,395.00 3,487.50 04/03/2024 NAB Review documents obtained in discovery 0.20 1,835.00 367.00 04/04/2024 DEB4 Conference with J. Kosciewicz regarding confidentiality issues (0.2); correspond with L. Song regarding same (0.1) 0.30 1,395.00 418.50 04/04/2024 DEB4 Participate in investigation update call with Kroll, L. Despins, N. Bassett 0.60 1,395.00 837.00 04/04/2024 DEB4 Correspond with A. Luft regarding certain

04/04/2024 DEB4 Correspond with L. Song regarding Kroll

04/04/2024 DEB4 Correspond with J. Barker regarding ROLF 0.20 1,395.00 279.00 04/04/2024 DEB4 Correspond with Swiss counsel regarding G

04/04/2024 DEB4 Correspond with L. Song regarding case

04/04/2024 DEB4 Correspond with N. Bassett regarding

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 110 of 700

Date Initials Description Hours Rate Amount

04/04/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,270.00 254.00 04/04/2024 ECS1 Review and comment on service of

supplemental Rule 2004 motion (.1);

Services) in connection with same (.1); review affidavit of service in connection

04/04/2024 JPK1 Correspond with N. Bassett regarding

04/04/2024 JPK1 Telephone call with D. Barron regarding applicability of protective order in Swiss proceeding (.2); review protective order (.3); email D. Barron regarding the same (.2) 0.70 1,185.00 829.50 04/04/2024 LAD4 Handle weekly Kroll investigation update call with N. Bassett and D. Barron 0.60 1,975.00 1,185.00 04/04/2024 LS26 Review foreign bank statement and determine confidentiality designation (0.6); correspond with P. Linsey (NPM) re Bering

04/04/2024 NAB Correspond with J. Kosciewicz regarding subpoena response (.1); correspond with L. Song regarding discovery issues (.2);

discovery issues (.3); review investigation diligence results (.4) 1.00 1,835.00 1,835.00 04/04/2024 NAB Meet with L.

regarding financial investigation 0.60 1,835.00 1,101.00 04/05/2024 DEB4 Correspond with M. McFarlane (Harneys) regarding BVI filings (0.3); analyze same

regarding same (0.2); correspond with L. Song regarding same (0.1) 1.10 1,395.00 1,534.50 04/05/2024 ECS1 Analyze G Club production documents and variances with Assignee documents (.3);

Date Initials Description Hours Rate Amount 04/05/2024 LAD4 Review & comment on UK proceeding/discovery (.70); t/c O. Brown (PH London office) re: same (.40) 1.10 1,975.00 2,172.50 04/05/2024 LS26 Correspond with P. Linsey (NPM) and D. Barron re Blackthorn production 0.40 985.00 394.00 04/06/2024 AB21 Review district court decision on HK USA discovery and sanctions 0.30 1,850.00 555.00 04/06/2024 NAB Review appellate decision affirming order of contempt and sanctions (.4); correspond with L. Despins regarding same (.2) 0.60 1,835.00 1,101.00 04/06/2024 NAB Correspond with P. Linsey (NPM) regarding discovery review and strategy (.3); review correspondence from Gibson Dunn regarding Brown Rudnick discovery (.2); correspond with E. Sutton regarding same (.1); correspond with L. Song regarding storage unit discovery (.1) 0.70 1,835.00 1,284.50 04/07/2024 AB21 Review Swiss case law related to recognition process (2.2); analyze Swiss-related transfers (0.8) 3.00 1,850.00 5,550.00 04/07/2024 DEB4 Correspond with N. Bassett regarding ROLF issues (0.1); correspond with E. Sutton regarding same (0.1) 0.20 1,395.00 279.00 04/07/2024 JPK1 Correspond with D. Barron regarding Rule of Law Society discovery 0.10 1,185.00 118.50 04/07/2024 NAB Correspond with L. Despins and D. Barron regarding discovery and investigation issues 0.30 1,835.00 550.50 04/08/2024 AB21 Review status of BVI investigation (0.5); prepare related summary chart (0.7); correspond with A. Thorp regarding same (0.1); correspond with E. Sutton related to Kwok's out of court tactics (0.1) 1.40 1,850.00 2,590.00 04/08/2024 DS50 Correspond with Y. Dhamee re Reverence fund interest 0.80 1,270.00 1,016.00 04/08/2024 DEB4 Correspond with N, Bassett and L. Despins regarding ROLF issues (0.1); correspond with J. Barker (Kroll) regarding same (0.1) 0.20 1,395.00 279.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 112 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount 04/08/2024 ECS1 Review and summarize Brown Rudnick documents related to clawback request (1.4); correspond with N. Bassett regarding same (.3); call with N. Bassett regarding same (.1); correspond with S. Phan (UnitedLex) regarding same (.2) 2.00 1,270.00 2,540.00 04/08/2024 JPK1 Telephone conference with D. Barron, E. Sutton, and L. Song regarding discovery issues and related tasks 1.00 1,185.00 1,185.00 04/08/2024 JPK1 Correspond with A. Lomas (Kroll) regarding bank accounts opened by Rule of Law Foundation and Rule of Law Society 0.20 1,185.00 237.00 04/08/2024 LS26 Review correspondence from informant (0.3); correspond with J. Barker (Kroll) re title search of potential asset (0.1); review documents from storage unit (2.2) 2.60 985.00 2,561.00 04/08/2024 NAB Correspond with E. Sutton regarding discovery issues (.3); telephone conference with E. Sutton regarding same (.1); review protective order and confidentiality issues (.2); correspond with J. Kosciewicz regarding motion relating to same (.2) 0.80 1,835.00 1,468.00 04/08/2024 NAB Correspond with P. Parizek (Kroll), L. Song regarding device and data review 0.10 1,835.00 183.50 04/08/2024 NAB Review and assess litigation issues and asset recovery efforts (.4); correspond with P. Linsey (NPM) regarding same (.2) 0.60 1,835.00 1,101.00 04/08/2024 SM29 Review District Court opinion on appeal 0.60 1,395.00 837.00 04/09/2024 AB21 Conference with D. Barron regarding BVI 0.50 1,850.00 925.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 113 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/09/2024 DEB4 Correspond with P. Linsey (NPM) regarding Aviation Trust Company (0.3); correspond with P. Linsey regarding G Club operations (0.1); conference with A. Bongartz regarding BVI entities (0.5);

regarding same (1.8); correspond with A. Thorp regarding new affidavit and related BVI filings (0.1); analyze same (1.0);

Blackthorn (.2) 4.10 1,395.00 5,719.50 04/09/2024 ECS1 Prepare chart summarizing information

regarding same (.2) 3.90 1,270.00 4,953.00 04/09/2024 ECS1 Review and summarize Brown Rudnick documents related to clawback request (.2); correspond with N. Bassett regarding same

documents from Brown Rudnick (.1);

regarding same (.1) 0.50 1,270.00 635.00 04/09/2024 ECS1 Call with P.

04/09/2024 JPK1 Prepare discovery packet related to Rule of

production regarding the same (1.8) 3.10 1,185.00 3,673.50 04/09/2024 LAD4 Continue to review/outline foreign collection strategy 1.90 1,975.00 3,752.50 04/09/2024 LS26 Prepare list of BVI entities related to the

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 114 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/09/2024 LS26 Call with A. Lomas (Kroll), J. Lazarus (Kroll) re bank transaction analysis (0.2);

re same (0.1); review correspondence from

document production (1.4) 2.00 985.00 1,970.00 04/09/2024 LS26 Review documents from storage unit (0.4);

04/09/2024 NAB Telephone conference with P. Parizek (Kroll) regarding device review (.2);

regarding discovery issues (.2); correspond with E. Sutton regarding same (.1) 0.50 1,835.00 917.50 04/10/2024 AB21 Call with A. Thorp (Harneys Legal), D.

investigation and next steps (0.5);

04/10/2024 AB21 Correspond with L. Despins regarding

04/10/2024 DS50 Correspond with Y. Dhamee re Reverence

04/10/2024 DEB4 Correspond with L. Despins and A. Bongartz regarding confidentiality issues and documents for Swiss counsel (0.3);

same (0.2);

with P. Linsey regarding bank discovery 0.80 1,395.00 1,116.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 115 of 700

Date Initials Description Hours Rate Amount

04/10/2024 DEB4 Correspond with L. Song regarding BVI entities (0.3); conference with L. Despins regarding new BVI pleadings (0.3); conference with A. Bongartz regarding BVI entities (0.3); conference with A. Bongartz, L. Song, and A. Thorp (Harneys) regarding

regarding same (0.2); correspond with E.

related to G Club (0.1) 1.70 1,395.00 2,371.50 04/10/2024 ECS1 Follow up review of subpoena and service

rule 2004 motion (.2); call with A. Fullerton (Roadway Moving) regarding same (.2);

Debtor affiliates and their connections with Roadway Moving (.7); correspond with A. Fullerton regarding same (.9) 2.00 1,270.00 2,540.00 04/10/2024 ECS1 Correspond with N. Bassett and S. Phan

documents related to clawback request 0.10 1,270.00 127.00 04/10/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.30 1,270.00 381.00 04/10/2024 ECS1 Analyze discovery issues

Kingdom based affiliates of the Debtor 0.10 1,270.00 127.00 04/10/2024 ECS1 Correspond with L. Song regarding analysis

regarding Debtor-affiliated BVI entities 0.10 1,270.00 127.00 04/10/2024 JK21 Update appeal tracking chart 0.60 565.00 339.00 04/10/2024 LAD4 Review & comment on Cirrus jet issues (.70); t/c D. Barron re: new BVI pleadings (.30); review/edit my affidavit re: same (for London apartment and K Legacy) (1.10); email to P. Wright (London barrister) re: 4.60 1,975.00 9,085.00

same (.20); outline strategy re: same (2.30)

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 116 of 700

Date Initials Description Hours Rate Amount

04/10/2024 LS26 Meeting with A. Bongartz, D. Barron, and

(0.5); review and revise BVI entity list (0.2);

domains used by Kwok entities (0.2) 0.90 985.00 886.50 04/10/2024 LS26 Review corporate documents of New

storage unit documents (1.1) 3.50 985.00 3,447.50 04/10/2024 NAB Review diligence and discovery updates

certain aircraft (.3); analyze authority related

(NPM) and L. Despins regarding same (.2) 0.70 1,835.00 1,284.50 04/11/2024 DEB4 Participate in investigation update call with Kroll, L. Despins, N. Bassett, and L. Song (.6); correspond with P. Linsey regarding

(Kroll) regarding law firm payments (0.4);

regarding Ferraris (0.2); conference with L.

documents (0.6); correspond with J. Barker (Kroll) regarding Ferrari (0.2) 2.90 1,395.00 4,045.50 04/11/2024 JPK1 Correspond with N. Bassett regarding

internal notes regarding the same (.2);

regarding the same (.1) 0.40 1,185.00 474.00 04/11/2024 LAD4 Handle weekly Kroll update call with N. Bassett, D. Barron, L. Song (.60); review & comment on Swiss proceeding issues (1.10) 1.70 1,975.00 3,357.50 04/11/2024 LS26 Call with D. Barron re New Dynamic

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 117 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount 04/11/2024 LS26 Meeting with Kroll, L. Despins, N. Bassett, D. Barron and P. Linsey (NPM) re investigation update (0.6); correspond with J. Guglielmi (ULX) re certain case documents (0.2); correspond with N. Bassett re same (0.1) 0.90 985.00 886.50 04/11/2024 LS26 Correspond with D. Barron re draft stipulation with Barnett on motorcycle 0.10 985.00 98.50 04/11/2024 NAB Review information pertaining to potential asset recovery 0.30 1,835.00 550.50 04/11/2024 NAB Further review motions in limine filed in criminal case (.6); review draft complaint to recover (.3) 0.90 1,835.00 1,651.50 04/11/2024 NAB Review inventory relating to recovered electronic devices and evaluate next steps (.4); telephone conference and correspond with P. Parizek (Kroll) regarding same (.3); telephone conference with L. Song regarding discovery issues (.2); correspond with W. Farmer regarding discovery review and depositions (.3) 1.20 1,835.00 2,202.00 04/11/2024 NAB Review correspondence from P. Parizek (Kroll) and certain documents in anticipation of investigation update call (.2); participate in telephone conference with Kroll, L. Despins, D. Barron, and L. Song regarding investigation update and strategy (.6) 0.80 1,835.00 1,468.00 04/11/2024 NAB Correspond with D. Barron regarding stipulation to recover motorcycle (.1); review and revise same (.2); review information from Kroll pertaining to same (.1); correspond with M. Conway (opposing counsel) regarding same (.1) 0.50 1,835.00 917.50 04/11/2024 WCF Call with W. Clark (ULX) regarding document batching and document review 0.10 1,390.00 139.00 04/12/2024 AB21 Correspond with B. Hobden (Harneys Legal) regarding Cayman investigation 0.10 1,850.00 185.00

04/12/2024 DEB4 Analyze case documents 3.20 1,395.00 4,464.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 118 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/12/2024 DEB4 Call with L. Fraser regarding Hamilton and Cayman entities (0.5); correspond with A. Lomas (Kroll) regarding funds tracing (0.5);

Dynamic (0.1); correspond with L. Despins regarding BVI affidavit (0.3); correspond with M. McFarlane regarding same (0.2); revise same (0.3); correspond with P. Linsey regarding Aviation Trust (0.1); correspond

04/12/2024 ECS1 Correspond with E. Cohn (Metro Attorney

Anzaldua (.1); review information regarding

transfer of Ducati from S. Barnett to the Debtor's estate (.9); correspond with D. Barron regarding same (.2) 1.10 1,270.00 1,397.00 04/12/2024 JPK1 Continue reviewing discovery related to

regarding Rule of Law bank accounts (.5);

information (.4) 1.90 1,185.00 2,251.50 04/12/2024 JPK1 Review A. Mitchell privilege log (.2); review

regarding certain representations (.2); correspond with A. Mitchell regarding the

04/12/2024 JPK1 Analyze authority regarding amendments to protective orders 1.30 1,185.00 1,540.50

Swiss proceeding issues 1.20 1,975.00 2,370.00 04/12/2024 LS26 Review documents re New Dynamic Development transactions (1.6); correspond with A. Lomas (Kroll) re same (0.2); correspond with D. Barron re same (0.4) 2.20 985.00 2,167.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 119 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/12/2024 WCF Correspond with UnitedLex (W. Clark)

UnitedLex document/data batching (.2); correspond with J. Kosciewicz, K. Catalano, E. Sutton, L. Song regarding same (.2) 0.40 1,390.00 556.00 04/13/2024 NAB Review correspondence from J. Barker (Kroll) regarding vehicle diligence 0.20 1,835.00 367.00 04/15/2024 AB21 Call with B. Hobden (Harneys Legal) and

04/15/2024 DEB4 Correspond with A. Lomas (Kroll) regarding New Dynamic accounts 0.10 1,395.00 139.50 04/15/2024 DEB4 Conference with A. Bongartz, B. Hobden,

investigation (0.4); prepare follow up notes regarding same (0.1) 0.50 1,395.00 697.50 04/15/2024 DEB4 Correspond with E. Sutton regarding

04/15/2024 DEB4 Correspond with L. Despins regarding 0.10 1,395.00 139.50 04/15/2024 DEB4 Correspond with L. Song regarding Cayman

04/15/2024 ECS1 Correspond with D. Barron regarding

protective order (.1); correspond with P.

connection with same (.1) 0.30 1,270.00 381.00 04/15/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,270.00 254.00 04/15/2024 JPK1 Draft parts of motion for amended protective order 1.90 1,185.00 2,251.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 120 of 700

Date Initials Description Hours Rate Amount

04/15/2024 NAB Correspond and telephone conference with

and review (.2); correspond with W. Farmer regarding document review (.2) 0.40 1,835.00 734.00 04/15/2024 WCF Review Rule 2004 investigation document/data batching for PH review (.2);

04/16/2024 AB21 Call with D. Hayek (Prager) and L. Despins

(0.2); further call with L. Despins regarding

04/16/2024 AB21 Call with A. Thorp (Harneys Legal)

regarding same (0.1) 0.30 1,850.00 555.00 04/16/2024 DEB4 Correspond with N. Bassett regarding

04/16/2024 DEB4 Correspond with L. Song regarding

04/16/2024 DEB4 Correspond with L. Song regarding Y.

04/16/2024 DEB4 Correspond with A. Lomas regarding bank

04/16/2024 DEB4 Conferences with M. McFarlane (Harneys) regarding BVI filings 0.10 1,395.00 139.50 04/16/2024 DEB4 Correspond with E. Sutton regarding

04/16/2024 DEB4 Correspond with L. Despins

04/16/2024 DEB4 Correspond with A. Singh regarding case

04/16/2024 DEB4 Correspond with L. Song regarding BVI

04/16/2024 DEB4 Revise UK discovery list 0.80 1,395.00 1,116.00

Date Initials Description Hours Rate Amount

04/16/2024 DEB4 Correspond with E. Sutton regarding UK

04/16/2024 DEB4 Correspond with L. Despins regarding

04/16/2024 DEB4 Correspond with L. Despins regarding precedent for Swiss counsel 0.10 1,395.00 139.50 04/16/2024 DEB4 Correspond with L. Song regarding Nevis

04/16/2024 DEB4 Conference with L. Song and E. Sutton regarding UK discovery 0.30 1,395.00 418.50 04/16/2024 ECS1 Correspond with D. Barron, J. Kosciewicz and P. Linsey (NPM) regarding parties who

04/16/2024 ECS1 Prepare responses to rule 2004 targets re

confers, and subpoenas 0.10 1,270.00 127.00 04/16/2024 ECS1 Analyze discovery issues related to United Kingdom-based affiliates of the Debtor (.3); prepare list of targets and summary of their role and relevance to Kwok (.2); call with D. Barron and L. Song regarding same (.3) 0.80 1,270.00 1,016.00 04/16/2024 JPK1 Draft parts of motion to amend protective order (3.7); analyze caselaw and statutory authority regarding the same (1.5) 5.20 1,185.00 6,162.00 04/16/2024 JPK1 Correspond with E. Sutton regarding signees to Exhibit A to the protective order 0.10 1,185.00 118.50 04/16/2024 LAD4 T/c A. Bongartz and D. Hayek (Swiss counsel) re: Swiss proceeding (.20); post mortem A. Bongartz (.10) 0.30 1,975.00 592.50 04/16/2024 LS26 Correspond with M. McFarlane (Harneys)

04/16/2024 LS26 Review documents re Y. Wang apartment

Date Initials Description Hours Rate Amount

04/16/2024 LS26 Call with D. Barron and E. Sutton re UK

04/16/2024 LS26 Meeting with P. Linsey (NPM), L. Despins, N. Bassett, and D. Barron re investigation

04/17/2024 AB21 Call with D. Barron regarding Nevis

04/17/2024 DEB4 Conference with L. Song regarding Anton

04/17/2024 DEB4 Call with A. Bongartz regarding Nevis

04/17/2024 DEB4 Correspond with P. Linsey (NPM) regarding Apostille for Swiss proceeding 0.10 1,395.00 139.50 04/17/2024 DEB4 Correspond with E. Sutton regarding Manhattan motorcars 0.20 1,395.00 279.00 04/17/2024 DEB4 Correspond with P. Linsey (NPM) regarding bank discovery 0.20 1,395.00 279.00 04/17/2024 DEB4 Correspond with E. Sutton regarding additional rule 2004 targets 0.20 1,395.00 279.00 04/17/2024 DEB4 Analyze investigation documents 0.50 1,395.00 697.50 04/17/2024 DEB4 Correspond with L. Despins

04/17/2024 DEB4 Conference with L. Song regarding storage

04/17/2024 DEB4 Correspond with L. Song regarding

04/17/2024 DEB4 Correspond with E. Sutton regarding Brown Rudnick documents 0.10 1,395.00 139.50 04/17/2024 DEB4 Conference with N. Bassett and L. Song regarding additional rule 2004 targets 0.10 1,395.00 139.50 04/17/2024 DEB4 Correspond with L. Despins regarding Anton Development 0.40 1,395.00 558.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 123 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/17/2024 ECS1 Correspond with D. Barron, J. Kosciewicz and P. Linsey (NPM) regarding parties who

correspondence re same (.1) 0.20 1,270.00 254.00 04/17/2024 ECS1 Review documents from G Club production (.1); correspond with W. Farmer

04/17/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,270.00 254.00 04/17/2024 ECS1 Prepare draft supplemental Rule 2004

investigation (.5); correspond with D. Barron and L. Song regarding same (.2); analyze information re potential additional targets for supplemental rule 2004 motion

04/17/2024 ECS1 Review Brown Rudnick supplemental

(.2); correspond with D. Barron regarding

04/17/2024 JPK1 Correspond with D. Barron regarding motion to amend protective order 0.20 1,185.00 237.00 04/17/2024 JPK1 Continue drafting motion to amend protective order 6.70 1,185.00 7,939.49 04/17/2024 JPK1 Prepare summary packet of Rule of Law

October through December 2022 0.70 1,185.00 829.50 04/17/2024 LAD4 Analyze/outline international collection 1.40 1,975.00 2,765.00

04/17/2024 LAD4 Analyze/outline international collection

04/17/2024 LS26 Review corporate documents and bank transactions of Anton Development (0.4); conference with D. Barron re same (0.3); review documents from storage units (1.8) 2.50 985.00 2,462.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 124 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount 04/17/2024 LS26 Call with J. Barker (Kroll) re domain and server searches (0.3); correspond with N. Bassett re same (0.1); conference with N. Bassett and D. Barron re Rule 2004 discovery (0.1); conference with D. Barron re storage unit contents (0.3); call and correspond with R. Saintil (Complete Legal) regarding box pickup and document scanning (0.3); meeting with S. Fung (Complete Legal) regarding same (0.2) 1.30 985.00 1,280.50 04/17/2024 NAB Telephone conference with D. Barron and L. Song regarding Rule 2004 issues (.1); correspond with L. Song regarding domain name issue (.1) 0.20 1,835.00 367.00 04/18/2024 DEB4 Conference with J. Kosciewicz regarding protective order motion (0.4); correspond with N. Bassett regarding same (0.1); analyze protective order (0.3) 0.80 1,395.00 1,116.00 04/18/2024 DEB4 Conference with Kroll, L. Despins, and L. Song regarding forensic analysis (0.9); correspond with L. Song regarding UK discovery (0.2); correspond with L. Song regarding informants (0.3); correspond with L. Song regarding Princes Gate (0.1); analyze investigation documents (2.8); correspond with A. Thorp regarding BVI entities (0.2); analyze issues related to ROLF/ROLS discovery (0.6) 5.10 1,395.00 7,114.50 04/18/2024 DEB4 Conference with P. Linsey (NPM) and Court Clerk regarding Apostille for Swiss proceeding (0.2); further conference with P. Linsey regarding same (0.1); correspond with L. Despins regarding UK proceedings (0.1) 0.40 1,395.00 558.00 04/18/2024 ECS1 Correspond with P. Linsey (NPM) regarding parties who have signed Exhibit A to the protective order (.1); review documents and correspondence in 0.30 1,270.00 381.00

> connection with same (.1); update list of parties in connection with same (.1)

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 125 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/18/2024 ECS1 Prepare draft supplemental Rule 2004

investigation (.1); correspond with D. Barron and L. Song regarding same (.1) 0.20 1,270.00 254.00 04/18/2024 ECS1 Prepare comprehensive chart of Kwok affiliated entities, information re same, and the Trustee's investigation in connection

04/18/2024 ECS1 Review documents from G Club production (.2); correspond with W. Clark

connection with same (.2) 0.40 1,270.00 508.00 04/18/2024 JPK1 Draft proposed order for motion to modify protective order (1.5); prepare exhibits for

04/18/2024 JPK1 Incorporate N. Bassett's comments to motion to modify protective order (1.7); review revised motion (.5) 2.20 1,185.00 2,607.00 04/18/2024 JPK1 Analyze Rule of Law Society and Rule of

regarding the same (1.7); call with L. Song regarding the same (.3); correspond with D. Barron regarding the same (.1) 2.10 1,185.00 2,488.50 04/18/2024 JPK1 Telephone call with D. Barron regarding motion to modify protective order 0.40 1,185.00 474.00 04/18/2024 LAD4 Handle weekly Kroll update call with D. Barron, L. Song (.90); t/c P. Linsey (NPM), P. Parizek (Kroll) re: data breach (.50) 1.40 1,975.00 2,765.00 04/18/2024 LS26 Prepare summary of UAE information (2.3); review bank statement production of

04/18/2024 LS26 Call with Kroll, P. Linsey (NPM), L.

ROLF/ROLS production (0.3) 1.20 985.00 1,182.00 04/18/2024 LS26 Correspond with D. Barron re investigation 0.20 985.00 197.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 126 of 700

Date Initials Description Hours Rate Amount

04/18/2024 NAB Review and revise draft motion to

protective order and obtain related relief (1.0); review order and case law related to

regarding same (.1); correspond with P. Parizek (Kroll) regarding data collection

04/19/2024 DM26 Prepare parts of rule 2004 target

04/19/2024 DEB4 Conference with A. Thorp (Harneys) and. L. Song regarding BVI law claims (0.8);

documents related to same (0.2) 1.00 1,395.00 1,395.00 04/19/2024 DEB4 Conference with L. Song regarding

04/19/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.10 1,270.00 127.00 04/19/2024 ECS1 Prepare comprehensive chart of Kwok affiliated entities, information re same, and the Trustee's investigation in connection

04/19/2024 ECS1 Correspond with D. Barron and L. Song

related to the Trustee's investigation 0.10 1,270.00 127.00 04/19/2024 ECS1 Prepare correspondence to rule 2004 targets

04/19/2024 ECS1 Review Brown Rudnick supplemental production documents 0.40 1,270.00 508.00 04/19/2024 JPK1 Correspond with L. Song regarding Raich Ende Malter Rule 2004 production (.2);

04/19/2024 JPK1 Telephone call with P. Linsey (NPM)

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 127 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/19/2024 LS26 Call with A. Thorp (Harneys) and D.

(0.2); correspond with A. Lomas (Kroll) and J. Barker (Kroll) re same (0.2); prepare list of Cayman Island entities (0.5) 4.30 985.00 4,235.50 04/19/2024 LS26 Call with D. Barron re UK Himalaya entities (0.4); review correspondence from informant re same (0.2) 0.60 985.00 591.00 04/20/2024 DEB4 Prepare discovery pleading for UK counsel 10.20 1,395.00 14,229.00 04/21/2024 DEB4 Correspond with L. Song regarding investigation issues (0.3); correspond with L. Song re UK discovery targets (0.5); call with L. Song re UK discovery targets (0.2);

from storage unit (0.2) 1.20 1,395.00 1,674.00 04/21/2024 LS26 Correspond with D. Barron re UK discovery targets (0.5); call with D. Barron

documents from storage unit (0.7); correspond with D. Barron re same (0.2); review public information on debtor related entities and debtor associates (0.6) 2.70 985.00 2,659.50

(0.2); analyze BVI law regarding same (0.3) 0.50 1,850.00 925.00 04/22/2024 CD16 Correspond with D. Barron and L. Despins re UK proceeding and discovery (0.6);

submissions from counsel re same (1.0); respond to queries from D. Barron and L. 2.00 1,395.00 2,790.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 128 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount 04/22/2024 DEB4 Correspond with L. Despins regarding Thorp affidavit in Switzerland (0.1); revise same (1.2); correspond with A. Bongartz regarding same (0.1); correspond with E. Sutton regarding rule 2004 motion (0.2); correspond with L. Song regarding D. Podhaskie (0.2); correspond with C. Daly regarding UK discovery (0.1); correspond with L. Despins regarding same (0.2); correspond with L. Song regarding Ashley Guillaume (0.1); correspond with L. Song regarding investigation update (0.2); analyze documents related to same (0.8) 3.20 1,395.00 4,464.00 04/22/2024 DEB4 Conference with P. Linsey (NPM), D. Salka (NPM), L. Despins, N. Bassett, and L. Song re investigation and litigation updates 0.90 1,395.00 1,255.50 04/22/2024 ECS1 Prepare draft supplemental Rule 2004 motion in connection with the Trustee's investigation (.8); correspond with D. Barron and L. Song regarding same (.2); analyze information re potential additional targets for supplemental rule 2004 motion (.3) 1.30 1,270.00 1,651.00 04/22/2024 ECS1 Prepare comprehensive chart of Kwok affiliated entities, information on same, and the Trustee's investigation related to same (.3); analyze documents and information re same (.4); correspond with D. Barron and L. Song re same (.1) 0.80 1,270.00 1,016.00 04/22/2024 ECS1 Correspond with N. Bassett regarding D. Podhaskie's production 0.20 1,270.00 254.00 04/22/2024 JPK1 Correspond with N. Bassett regarding motion to modify protective order 0.10 1,185.00 118.50 04/22/2024 JPK1 Correspond with A. Mitchell regarding Rule 2004 privilege log 0.10 1,185.00 118.50 04/22/2024 JPK1 Review and incorporate edits from N. Bassett on motion to modify the protective order (.4); correspond with L. Despins regarding the same (.1) 0.50 1,185.00 592.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 129 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/22/2024 LAD4 Review/edit draft protective motion modifications (.90); review/edit draft UK discovery pleading (.90); review/edit draft

proceeding (1.10) 2.90 1,975.00 5,727.50 04/22/2024 LAD4 Handle NPM weekly call with N. Bassett, L. Song, D. Barron 0.90 1,975.00 1,777.50 04/22/2024 LS26 Review documents regarding potential assets in Switzerland (0.4); correspond with A. Bongartz re same (0.2) 0.60 985.00 591.00 04/22/2024 LS26 Meeting with P. Linsey (NPM), D. Salka (NPM), L. Despins, N. Bassett and D. Barron re investigation update 0.90 985.00 886.50 04/22/2024 NAB Correspond with L. Song regarding

and information related to internet domains (.3); review certain documents uploaded to data room (.5); correspond with L. Despins regarding same (.1); review revised draft of motion to modify protective order (.3);

regarding same (.1) 1.70 1,835.00 3,119.50 04/22/2024 NAB Call with P. Linsey (NPM), D. Skalka (NPM), L. Despins, D. Barron, and L. Song regarding case updates and strategy 0.90 1,835.00 1,651.50 04/23/2024 AB21 Review Harneys Legal memo on Cayman Island investigation 0.20 1,850.00 370.00 04/23/2024 AB21 Revise declaration in support of Swiss recognition application 1.00 1,850.00 1,850.00 04/23/2024 CD16 Further review UK court documents and submissions from counsel (1.0); call with D. Barron re next stages in UK process (.8) 1.80 1,395.00 2,511.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 130 of 700

Date Initials Description Hours Rate Amount

04/23/2024 DEB4 Conference with C. Daly regarding UK discovery issues (0.8); correspond with C. Daly regarding same (0.1); correspond with

documents related to same (0.6) 1.60 1,395.00 2,232.00 04/23/2024 DEB4 Review investigation documents 1.00 1,395.00 1,395.00 04/24/2024 AB21 Call with D. Barron regarding Cayman Island investigation and next steps 0.10 1,850.00 185.00 04/24/2024 AB21 Revise declaration in support of Swiss recognition application (0.6); correspond with L. Despins regarding same (0.2); review draft recognition application (1.0) 1.80 1,850.00 3,330.00 04/24/2024 CD16 Correspond with D. Barron re relief

filings re transcripts (0.4); correspond with

judgment re English recognition of L. Despins (0.7); correspond with L. Despins

04/24/2024 DS50 Review Reverence fund documents (.5); draft summary of same (.1) 0.60 1,270.00 762.00 04/24/2024 DEB4 Correspond with N. Bassett and L. Despins

regarding same (0.1); correspond with E. Sutton regarding Hamiton SPC (0.1);

04/24/2024 DEB4 Review and comment on analysis from A.

regarding Apostille (0.1); correspond with M. Meili (Prager Dreifuss) regarding same 0.50 1,395.00 697.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 131 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount 04/24/2024 DEB4 Prepare UK discovery documents (2.2); correspond with L. Song regarding same (0.1); correspond with L. Despins regarding same (0.2); correspond with C. Daly regarding UK proceeding (0.1); analyze UK recognition order (0.7); correspond with A. Bongartz regarding BVI affidavit by Andrew Thorpe (0.1); revise same (0.5); correspond and conference with L. Song regarding A. Mitchell privilege log (0.3); call with J. Kosciewicz regarding same (0.2); correspond with N. Bassett regarding same (0.1); conference with A. Bongartz regarding Cayman discovery (0.1); analyze memo from Cayman counsel related to same (0.3); correspond with A. Bongartz on Swiss proceedings issues (0.3); correspond with A. Bongartz regarding Cayman entity and next steps in Cayman investigation (0.2); correspond with E. Sutton re: same (0.1) 5.50 1,395.00 7,672.50 04/24/2024 JPK1 Telephone call with D. Barron regarding A. Mitchell privilege log 0.20 1,185.00 237.00 04/24/2024 LS26 Review and revise draft UK discovery memorandum (2.1); correspond with D. Barron re same (0.1) 2.20 985.00 2,167.00 04/24/2024 LS26 Review A. Mitchell privilege log (0.9); correspond and call with D. Barron re same (0.3); review storage unit documents (1.6) 2.80 985.00 2,758.00 04/24/2024 NAB Review rule 2004 target privilege log (.3); correspond with J. Kosciewicz regarding same and next steps (.3) 0.60 1,835.00 1,101.00 04/24/2024 NAB Review comments to protective order motion and correspond with J. Kosciewicz regarding same 0.20 1,835.00 367.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 132 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/25/2024 AB21 Prepare comments to Swiss recognition application (1.9); correspond with L.

with L. Despins regarding same (0.5); revise related declaration (1.4); call with D. Barron regarding same (0.1); correspond with A.

opinion on bare trustee principles (0.1) 4.10 1,850.00 7,585.00 04/25/2024 DEB4 Correspond with A. Thorp (Harneys Legal)

proceeding (0.4); conference with A. Bongartz re same (0.1); correspond with A.

regarding UAE intelligence (0.2);

protective order (0.1); correspond with C. Daly regarding UK discovery case law (0.1);

Mitchel (0.2); analyze case law on UK issues

04/25/2024 DEB4 Conference with N. Bassett and L. Song

investigation issues and plan for same (1.2);

bank documents (0.2); correspond with E. Sutton regarding investigation targets (0.2);

discovery (0.1); correspond with A. Bongartz regarding same (0.1); correspond

declaration for Swiss counsel (0.3) 3.00 1,395.00 4,185.00 04/25/2024 ECS1 Correspond with D. Barron re rule 2004

investigation targets 0.30 1,270.00 381.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 133 of 700

Date Initials Description Hours Rate Amount

04/25/2024 ECS1 Analyze information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.40 1,270.00 508.00 04/25/2024 ECS1 Correspond with P. Linsey (NPM)

04/25/2024 ECS1 Correspond with A. Bongartz regarding information regarding Qiang Guo 0.20 1,270.00 254.00 04/25/2024 ECS1 Review discovery documents produced in

04/25/2024 ECS1 Review Brown Rudnick supplemental

documents (.5); correspond with N. Bassett and D. Barron regarding same (.2) 2.80 1,270.00 3,556.00 04/25/2024 LAD4 Handle Kroll weekly update call with L. Song, N. Bassett (.50); review/edit Swiss declaration supporting docs (2.30); meeting with A. Bongartz re: same (.50); t/c N. Bassett re: law firm claims (.20) 3.50 1,975.00 6,912.50 04/25/2024 LS26 Analyze and prepare memo

discovery (1.2); review documents regarding UAE info (0.2); correspond with P. Parizek (Kroll) regarding electronic devices analysis (0.2); review list of counsel in Kwok-related litigation (0.2); review documents re Qiang

Golden Spring storage unit documents (0.6) 2.70 985.00 2,659.50 04/25/2024 LS26 Meeting with Kroll, L. Despins, N. Bassett,

update (0.5); correspond with N. Bassett re Golden Spring documents (0.3); correspond

with D. Barron re potential assets in 1.10 985.00 1,083.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 134 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount 04/25/2024 NAB Analyze law firm litigation claims (.5); review documents related to same and prepare for potential meeting concerning same (1.4); call with L. Despins regarding same (.2); call with D. Barron and L. Song regarding same and related investigation issues (.4); further analysis relating to law firm litigation claims (.4); correspond with P. Linsey (NPM) regarding confidentiality issues (.2); call with P. Linsey regarding same (.1); call with Kroll, L. Despins, L. Song regarding case updates and strategy (.5); review documents produced in discovery from Golden Spring (.7); correspond with L. Song regarding same and next steps (.1) 4.50 1,835.00 8,257.50 04/25/2024 SK35 Correspond with W. Farmer regarding Rule 2004 investigation and next steps in Rul 2004 discovery 0.10 985.00 98.50 04/26/2024 AB21 Continue to revise Swiss recognition application, related declaration, and related documents (2.7); correspond with L. Despins regarding same (0.2); correspond with A. Thorp regarding related BVI declaration (0.1) 3.00 1,850.00 5,550.00 04/26/2024 CD16 Review email from D. Barron re UK proceeding and discovery (0.3); analyze case law on limitations of s236 (2.2) 2.50 1,395.00 3,487.50 04/26/2024 DEB4 Correspond with N. Bassett regarding Brown Rudnick documents (0.1); conference with L. Song regarding same (0.1); correspond with N. Bassett regarding pleadings related to same (0.4); conference with L. Despins regarding UK issues (0.3) 0.90 1,395.00 1,255.50 04/26/2024 DEB4 Analyze deposition transcripts in connection with potential law firm claims 1.70 1,395.00 2,371.50 04/26/2024 ECS1 Call with W. Farmer, K. Catalano, S. Kim, and J. Kosciewicz regarding review of discovery documents 0.30 1,270.00 381.00 Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 135 of 700

Date Initials Description Hours Rate Amount

04/26/2024 ECS1 Review documents from G Club production (2.0); correspond with W. Clark

connection with same (.1) 2.10 1,270.00 2,667.00 04/26/2024 JPK1 Attend telephone conference with W. Farmer, E. Sutton, K. Catalano, and S. Kim

04/26/2024 KC27 Attend meeting with W. Farmer, E. Sutton,

04/26/2024 LAD4 Call with UK barrister Paul Wright re: UK strategies on collection issues (.50); review

(.30); t/c P. Linsey (NPM) re: claims against Lawall/Pepper (.40) 2.60 1,975.00 5,135.00 04/26/2024 LS26 Analyze Brown Rudnick document production (3.3); conference with D. Barron regarding same (0.1) 3.40 985.00 3,349.00 04/26/2024 LS26 Analyze documents relating to Weihua Li 0.40 985.00 394.00 04/26/2024 NAB Analyze case law concerning potential

claims (1.6); review documents produced in

analysis of potential claims and settlement strategy (1.8); correspond with D.

and L. Song regarding same (.3) 5.00 1,835.00 9,175.00 04/26/2024 SK35 Conference with W. Farmer, E. Sutton, K. Catalano, and J. Kosciewicz regarding rule 2004 document review and review protocol 0.30 985.00 295.50 04/26/2024 WCF Prepare notes for Rule 2004 document review call (.1); call re Rule 2004 document review protocol and next steps with K. Catalano, E. Sutton, S. Kim and J.

04/27/2024 JPK1 Draft email to A. Mitchell regarding his

with N. Bassett regarding the same (.1) 0.40 1,185.00 474.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 136 of 700

Date Initials Description Hours Rate Amount

04/27/2024 NAB Analyze potential claims and related settlement strategy (1.0); review documents produced in discovery and analyze case law

with L. Song regarding same (.2) 1.70 1,835.00 3,119.50 04/28/2024 LS26 Continue to review Brown Rudnick document production 3.00 985.00 2,955.00 04/28/2024 NAB Further analyze potential claims and related settlement strategy (1.0); review documents produced in discovery and analyze case law

with L. Song regarding same (.2) 1.70 1,835.00 3,119.50 04/29/2024 AB21 Revise Swiss recognition application and related documents (2.0); correspond with L.

with M. Meili (Prager) regarding same (0.1); calls with D. Barron regarding same (0.4); call with L. Despins regarding same (0.2) 3.20 1,850.00 5,920.00 04/29/2024 CD16 Call with G. Salva re cases relating to English bankruptcy trustee powers (0.2); correspond with G. Salva re same (0.2); review same (0.8) 1.20 1,395.00 1,674.00 04/29/2024 CD16 Draft email to D. Barron re case law

investigative powers in England 1.50 1,395.00 2,092.50 04/29/2024 CD16 Review email from D. Barron re scope of trustee bankruptcy powers in England (0.3); call with D. Barron re same (0.4); review note on antecedent transactions in English 1.50 1,395.00 2,092.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 137 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount 04/29/2024 DEB4 Correspond with N. Bassett regarding Brown Rudnick issues (0.3); correspond with L. Song regarding Swiss bank accounts (0.1); conferences with A. Bongartz regarding same and Swiss recognition documents (0.4); correspond with L. Song regarding UK discovery pleading (0.2); revise same (0.6) conference with C. Daly regarding UK issues (0.4); analyze authorities related to same (1.2); correspond with L. Despins regarding same (0.1); correspond with L. Song regarding GFNY documents (0.2); correspond with P. Linsey regarding ADP documents (0.3); correspond with L. Song and N. Bassett regarding storage unit documents (0.2) 4.00 1,395.00 5,580.00 04/29/2024 JPK1 Correspond with L. Song regarding storage unit documents 0.10 1,185.00 118.50 04/29/2024 JPK1 Review documents produced in response to Rule 2004 requests 0.90 1,185.00 1,066.50 04/29/2024 JPK1 Correspond with P. Linsey (NPM) regarding confidentiality designations on Rule 2004 productions 0.10 1,185.00 118.50 04/29/2024 LAD4 Review/edit Swiss supporting documents (2.60); t/c A. Bongartz re: same (.20); emails to/from A. Bongartz re: same (.20) 3.00 1,975.00 5,925.00 04/29/2024 LAD4 Handle weekly NPM call with D. Barron, L. Song, N. Bassett 0.90 1,975.00 1,777.50 04/29/2024 LS26 Review ADP production (0.4); correspond with P. Linsey (NPM) and D. Barron re 0.50 985.00 492.50 Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 138 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

Date Initials Description Hours Rate Amount

04/29/2024 LS26 Review documents from storage unit (3.9); correspond with N. Bassett re same (0.3);

(0.2); correspond with D. Barron re potential assets in Switzerland

regarding storage unit documents (0.1);

transactions involving law firms (0.3) 5.00 985.00 4,925.00 04/29/2024 NAB Review documents produced in discovery in

settlement strategy (1.5); analyze potential claims and prepare outline for same (1.6);

documents (.6); review email from L. Song regarding same (.1); correspond with D. Barron regarding analysis of potential claims

regarding discovery issues (.3); correspond

processing (.1) 4.80 1,835.00 8,808.00 04/29/2024 NAB Correspond with M. Conway (Barnett counsel) regarding Ducati stipulation (.1);

with L. Despins regarding same (.1) 0.40 1,835.00 734.00 04/30/2024 AB21 Correspond with A. Thorp (Harneys Legal) regarding update on BVI investigation (0.2);

Cayman investigation (0.4) 0.60 1,850.00 1,110.00 04/30/2024 CD16 Analyze Kireeva case 0.50 1,395.00 697.50 04/30/2024 DEB4 Correspond with L. Song and N. Bassett regarding investigation documents (0.3); analyze same (1.4) 1.70 1,395.00 2,371.50 04/30/2024 DEB4 Correspond with N. Bassett regarding

04/30/2024 JPK1 Correspond with A. Mitchell regarding Rule 2004 privilege log 0.10 1,185.00 118.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 139 of 700

Date Initials Description Hours Rate Amount

04/30/2024 JPK1 Correspond with P. Linsey (NPM) regarding Rule 2004 discovery updates 0.20 1,185.00 237.00 04/30/2024 LAD4 Review device issues handled by Kroll (.50); t/c P. Linsey (NPM) re: UK litigation issues

04/30/2024 LS26 Call with N. Bassett, P. Parizek (Kroll), and

forensic analysis (1.2); call and correspond

electronic data inventory list (0.3) 1.80 985.00 1,773.00 04/30/2024 LS26 Review storage unit documents (1.4);

04/30/2024 LS26 Review electronic device summary chart from Kroll (0.3); call and correspond with

(NPM) re domain searches (0.7) 1.00 985.00 985.00 04/30/2024 NAB Further analyze potential professional

(1.5); review evidence concerning same (.9); review caselaw concerning same (.7); call with L. Song, P. Parizek (Kroll) regarding

(1.2); review results from same (.9); correspond and call with L. Song regarding

preservation issues (.2); correspond with L. Despins, L. Song, and D. Barron regarding additional claims against professionals (.1) 7.70 1,835.00 14,129.50 04/30/2024 SK35 Review background documents to prepare

2004 investigations 1.30 985.00 1,280.50 Subtotal: B261 Investigations 328.30 463,928.99

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2403068

ID Timekeeper Name Title Hours Rate Fee

YID Yousuf I. Dhamee Partner 0.70 1,985.00 1,389.50 LAD4 Luc A. Despins Partner 36.00 1,975.00 71,100.00 NAB Nicholas A. Bassett Partner 51.80 1,835.00 95,053.00 AB21 Alex Bongartz Of Counsel 22.90 1,850.00 42,365.00 CD16 Crispin Daly Associate 12.80 1,395.00 17,856.00 DEB4 Douglass E. Barron Associate 110.30 1,395.00 153,868.50 SM29 Shlomo Maza Associate 0.90 1,395.00 1,255.50 WCF Will C. Farmer Associate 1.80 1,390.00 2,502.00 ECS1 Ezra C. Sutton Associate 36.00 1,270.00 45,720.00 DS50 Daniel Sylvia Associate 3.00 1,270.00 3,810.00 KC27 Kristin Catalano Associate 8.30 1,185.00 9,835.50 JPK1 Jon P. Kosciewicz Associate 35.70 1,185.00 42,304.50 LS26 Luyi Song Associate 74.00 985.00 72,890.00 SK35 Sarah Kim Associate 1.70 985.00 1,674.50 DM26 David Mohamed Paralegal 7.30 565.00 4,124.50 JK21 Jocelyn Kuo Paralegal 1.30 565.00 734.50

Date Description Quantity Rate Amount

04/24/2024 Photocopy Charges 188.00 0.08 15.04 04/25/2024 Photocopy Charges 32.00 0.08 2.56 04/25/2024 Photocopy Charges (Color) 182.00 0.20 36.40

Invoice# 41609 Dated 04/01/24, Service of a subpoena on Aviation Trust Company 269.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 141 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 40

04/01/2024 Electronic Document Retrieval -

and Alternative Data Solutions, Inc., Invoice# 1047352-202403-1 Dated 04/01/24, TLO Charges

Person Search/Comprehensive Report 80.00

Nick Bassett; 03/18/2024; From/To: DCA/LGA; Airfare Class: Economy; Travel to New York and Connecticut for Kwok mediation hearing 753.20

Nick Bassett; 03/19/2024; Restaurant: DCA Wow; City: Washington, DC; Coffee; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 10.27

Nick Bassett; 03/19/2024; Restaurant: Kavaldi Coffee; City: New York; Coffee; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 21.59

Nick Bassett; 03/19/2024; Restaurant: LGA Bar Veloce; City: New York; Dinner; Number of people: 1; Travel to New York and Connecticut for Kwok mediation hearing 28.53

Nick Bassett; 03/19/2024; Restaurant: Georgetown Gourmet Market; City: New York; Coffee; Number of people: 1; Travel to New York and Connecticut for Kwok mediation

Nick Bassett;

Bridgeport/LGA; Service Type: Uber; Travel to New York and Connecticut for Kwok mediation

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 142 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 41

Nick Bassett; 03/19/2024; From/To: LGA/Bridgeport; Service Type: Uber; Travel to New York and Connecticut

Nick Bassett; 03/19/2024; From/To: home/DCA; Service Type: Uber; Travel to New York and Connecticut for

Nick Bassett; 03/20/2024; From/To: DCA/Home; Service Type:

04/04/2024 Outside Professional Services -

Services, LLC, Invoice# 04042024SB1 Dated 04/04/24, moving services provided on April 3 and April 4 to move storage unit contents to the Mahwah Mansion pursuant to Court order 3,510.00 04/05/2024 Outside Professional Services -

Services, LLC, Invoice# 04052024SB1 Dated 04/05/24, moving services provided on April 5 to move storage unit contents per Court order 2,555.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 143 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 42

Ezra Sutton; 03/26/2024; Restaurant: Smash house; City: New York ; dinner; Number of people: 1; Late night meal re work on

Luyi Song; 04/03/2024; From/To: NJ/NY; Service Type: Lyft; Time: 15:47; Travel from New Jersey to New York after supervising move of storage unit content 100.04

Luyi Song; 04/04/2024; From/To: NY/NJ; Service Type: Lyft; Time: 08:29; Travel from New York to New Jersey

Luyi Song; 04/05/2024; From/To: NY/NJ; Service Type: Lyft; Time: 08:04; Travel from New York to New Jersey

Luyi Song; 04/03/2024; From/To: NY/NJ; Service Type: Lyft; Time: 08:13; Travel from New York to New Jersey

Luyi Song; 04/05/2024; Travel from New Jersey to New York after supervising move of storage unit content 9.75

Luyi Song; 04/04/2024; From/To: NJ/NY; Service Type: Uber; Time: 15:55; Travel from New Jersey to New

after supervising move of storage unit content 97.02

Luc Despins;

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 43

Luc Despins;

20240429PT Dated 04/29/24, company search fee on 11 April 2024 for New Dynamic Development

Total Costs incurred and advanced \$51,105.04

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Other Litigation PH LLP Client/Matter # 50687-00003 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$98,145.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Other Litigation PH LLP Client/Matter # 50687-00003 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$98,145.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 147 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 12, 2024

Date Initials Description Hours Rate Amount

04/01/2024 AB21 Prepare notice of United States response to

regarding same (0.2); correspond with J.

04/01/2024 JK21 Correspond with A. Bongartz regarding filing of notice of filing Government's letter

to Y. Wang rule 16 motion (0.1); prepare for electronic filing notice of filing

rule 16 motion (0.1); electronically file with

letter response to Y. Wang rule 16 motion (0.1);

filing Government's letter response to Y. Wang rule 16 motion (0.2) 0.50 565.00 282.50 04/01/2024 JK21 Correspond with L. Despins regarding Kwok criminal case recent filings 0.20 565.00 113.00 04/01/2024 LAD4 Review J. Torres decision denying motion to dismiss (RICO) 0.90 1,975.00 1,777.50

Date Initials Description Hours Rate Amount

04/01/2024 LS26 Review government briefs in criminal case 0.50 985.00 492.50 04/01/2024 NAB Review new filings in criminal case (.4); correspond with L. Despins and A. Bongartz regarding same (.1) 0.50 1,835.00 917.50 04/02/2024 DEB4 Analyze criminal case filings (0.4); correspond with P. Linsey (NPM) and N. Bassett regarding same (0.2) 0.60 1,395.00 837.00 04/02/2024 ECS1 Analyze caselaw and statutory authority regarding criminal forfeiture of assets and

the debtor's assets 1.00 1,270.00 1,270.00 04/02/2024 NAB Review criminal court order denying motion to dismiss 0.30 1,835.00 550.50 04/03/2024 DEB4 Analyze criminal case filing 0.30 1,395.00 418.50 04/03/2024 ECS1 Correspond with D. Barron regarding order

04/03/2024 JPK1 Correspond with N. Bassett regarding grand jury subpoena dated March 22, 2024 0.20 1,185.00 237.00 04/03/2024 LAD4 Call with DOJ and A. Luft re: trial 0.80 1,975.00 1,580.00 04/04/2024 DM26 Research and update spreadsheet regarding returned mail related to service of pleadings

returned mail regarding additional pleadings

04/04/2024 ECS1 Analyze caselaw regarding criminal

bankruptcy and distribution of the debtor's

04/05/2024 JK21 Correspond with L. Despins regarding Kwok criminal case recent filings 0.10 565.00 56.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 149 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2403069

Date Initials Description Hours Rate Amount

04/05/2024 JPK1 Correspond with N. Bassett regarding

subpoena (.3); draft revised cover letter for response to grand jury subpoena (.5); review

(NPM) regarding the same (.1); correspond with D. Mohamed regarding the same (.2);

Department of Justice (.2) 1.70 1,185.00 2,014.50 04/05/2024 NAB Correspond with J. Kosciewicz regarding DOJ subpoena response (.2); review letter to DOJ regarding same (.2) 0.40 1,835.00 734.00 04/07/2024 DEB4 Correspond with L. Despins regarding

04/08/2024 DEB4 Correspond with L. Despins regarding DOJ documents (0.1); correspond with E. Sutton

04/08/2024 ECS1 Review documents related to Trustee's

with DOJ subpoena of the Trustee (2.4);

04/08/2024 JK21 Correspond with L. Despins regarding

04/08/2024 NAB Review criminal case correspondence and

04/08/2024 NAB Correspond with L. Despins regarding criminal case filings 0.20 1,835.00 367.00 04/09/2024 DEB4 Correspond with L. Song regarding criminal case issues (0.3); correspond with N. Bassett regarding criminal case filings (0.1); correspond with L. Despins regarding DOJ 0.90 1,395.00 1,255.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 150 of 700

Date Initials Description Hours Rate Amount

04/09/2024 ECS1 Review documents related to Trustee's

with DOJ subpoena of the Trustee (.2);

regarding same (.1) 0.30 1,270.00 381.00 04/09/2024 JK21 Correspond with L. Despins regarding

04/09/2024 NAB Review criminal case filings 0.60 1,835.00 1,101.00 04/10/2024 DEB4 Analyze criminal case pleadings (1.2);

04/10/2024 DEB4 Correspond with L. Despins regarding DOJ documents (0.2); correspond with J. Murray regarding documents for DOJ (0.2) 0.40 1,395.00 558.00 04/10/2024 ECS1 Analyze caselaw regarding criminal

bankruptcy and distribution of the debtor's assets (.3); call with S. Maza regarding same

04/10/2024 JK21 Correspond with L. Despins regarding

04/10/2024 LAD4 Review motions in limine in criminal case 1.20 1,975.00 2,370.00 04/10/2024 LS26 Review government's motion in limine in

04/10/2024 NAB Review motions in limine and additional filings in criminal case (.7); correspond with

appellate deadlines for same (.1) 1.00 1,835.00 1,835.00 04/10/2024 SM29 Analyze caselaw and statutory authority re forfeiture issues (4.4); call with E. Sutton re same (.2); email L. Despins re same (.1) 4.70 1,395.00 6,556.50 04/11/2024 DEB4 Call with L. Song regarding government

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 151 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2403069

Date Initials Description Hours Rate Amount

04/11/2024 ECS1 Analyze caselaw and statutory authority regarding criminal forfeiture of assets and

the debtor's assets (2.7); prepare summary

with S. Maza regarding same (.2) 3.50 1,270.00 4,445.00 04/11/2024 JK21 Correspond with L. Despins regarding

04/11/2024 LS26 Call with D. Barron re government's motion in limine in criminal case (0.7); prepare summary of same (1.7) 2.40 985.00 2,364.00 04/11/2024 SM29 Analyze forfeiture issues and related case law and statutory authority (4.9); call and

04/12/2024 ECS1 Analyze caselaw and statutory authority regarding criminal forfeiture of assets and

the debtor's assets (1.3); prepare summary regarding same (.6); correspond with S. Maza regarding same (.1) 2.00 1,270.00 2,540.00 04/12/2024 NAB Review filings in criminal case 0.30 1,835.00 550.50 04/12/2024 SM29 Review forfeiture outline from E. Sutton (.7); email E. Sutton re same (.1); further

authority (3.0); further correspond with E. Sutton re same (.2) 4.00 1,395.00 5,580.00 04/14/2024 ECS1 Analyze caselaw re criminal forfeiture of

distributions of the debtor's assets (1.2);

with S. Maza regarding same (.1) 1.60 1,270.00 2,032.00 04/15/2024 ECS1 Analyze caselaw and statutory authority re criminal forfeiture of assets and the impact

debtor's assets (3.4); prepare summary of same (1.0); correspond with S. Maza 4.80 1,270.00 6,096.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 152 of 700

Date Initials Description Hours Rate Amount

04/15/2024 JK21 Correspond with L. Despins regarding recently filed pleadings in Kwok criminal

04/15/2024 SM29 Review and revise forfeiture issues list from

04/16/2024 ECS1 Analyze caselaw and statutory authority regarding criminal forfeiture of assets and the impact on bankruptcy and distributions of the debtor's assets (3.9); prepare outline regarding same (1.7); correspond with S. Maza regarding same (.2) 5.80 1,270.00 7,366.00 04/16/2024 JK21 Correspond with E. Sutton regarding forfeiture research outline 0.20 565.00 113.00 04/17/2024 JK21 Correspond with L. Despins regarding recently filed pleadings in Kwok criminal

04/18/2024 ECS1 Analyze authority re criminal forfeiture of

distributions of the debtor's assets (1.5); prepare outline summarizing same (.8);

04/18/2024 JK21 Correspond with L. Despins regarding recently filed pleadings in Kwok criminal

04/18/2024 LS26 Review government's opposition brief to defendants' motion in limine 0.80 985.00 788.00 04/18/2024 SM29 Review updated forfeiture memo from E. Sutton (.8); correspond with E. Sutton re

04/19/2024 DEB4 Analyze documents related to forfeiture

regarding same (0.5) 1.30 1,395.00 1,813.50 04/19/2024 DEB4 Correspond with L. Song regarding government pleadings 0.20 1,395.00 279.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 153 of 700

Date Initials Description Hours Rate Amount

04/19/2024 ECS1 Analyze criminal forfeiture of assets and the impact on bankruptcy and distributions of the debtor's assets (.9); correspond with S. Maza regarding same (.2) 1.10 1,270.00 1,397.00 04/19/2024 LAD4 T/c with DOJ team re: Anton Development, AIG litigation 0.40 1,975.00 790.00 04/19/2024 SM29 Prepare memorandum to L.

forfeiture issues (3.3); analyze same and related authority (1.0); call with D. Barron

04/22/2024 LAD4 Review criminal case motions/objections 1.50 1,975.00 2,962.50 04/22/2024 LS26 Review and prepare summary of criminal

04/24/2024 NAB Review criminal case filings (.2); correspond with L. Despins regarding same (.1) 0.30 1,835.00 550.50 04/25/2024 DEB4 Correspond with L. Song regarding superseding indictment 0.10 1,395.00 139.50 04/29/2024 PBA Correspond with L. Despins regarding DOJ

04/30/2024 LS26 Review criminal case docket update 0.20 985.00 197.00 Subtotal: B191 General Litigation 73.40 98,145.50

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 4.80 1,975.00 9,480.00 NAB Nicholas A. Bassett Partner 3.70 1,835.00 6,789.50 PBA Peter B. Axelrod Partner 0.10 1,775.00 177.50

SM29 Shlomo Maza Associate 20.20 1,395.00 28,179.00 DEB4 Douglass E. Barron Associate 6.60 1,395.00 9,207.00 ECS1 Ezra C. Sutton Associate 26.30 1,270.00 33,401.00 Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 154 of 700

50687-00003 Luc Despins as Chapter 11 Trustee in the case of Ho Wan

JPK1 Jon P. Kosciewicz Associate 1.90 1,185.00 2,251.50 LS26 Luyi Song Associate 5.60 985.00 5,516.00 JK21 Jocelyn Kuo Paralegal 2.50 565.00 1,412.50 DM26 David Mohamed Paralegal 1.10 565.00 621.50

Date Description Quantity Rate Amount

2-258-29543 Rongrong Li 2 Gatliff Road 79 Moor House London SW1W8-QN GB; Dated 04/02/24, Packages from various persons going to various 21.66 Total Costs incurred and advanced \$21.66

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 155 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Tax Issues PH LLP Client/Matter # 50687-00006 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$13,380.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 156 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Tax Issues PH LLP Client/Matter # 50687-00006 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$13,380.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 157 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 12, 2024

FOR PROFESSIONAL SERVICES RENDERED for the period ending April 30, 2024

Date Initials Description Hours Rate Amount

04/01/2024 AB21 Call with E. Sutton regarding tax questions

04/01/2024 ECS1 Analyze records in response to questions

questions (.5); correspond with A. Bongartz regarding same (.3); call with T. Sadler in connection with same (.1) 2.70 1,270.00 3,429.00 04/02/2024 AB21 Call with E. Sutton regarding tax questions

04/02/2024 ECS1 Analyze records in response to questions

regarding same (.1) 1.50 1,270.00 1,905.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 158 of 700

Finalize tax extension vouchers (0.2); correspond with L. Despins regarding same (0.1); call and correspond with J.

questions (0.8) 1.20 1,850.00 2,220.00 04/03/2024 ECS1 Analyze records in connection with

preparation of estate taxes 0.10 1,270.00 127.00 04/04/2024 AB21 Review updated responses to EA Group's

regarding same (0.1); correspond with J.

(0.1); call with J. Lindenberg regarding tax filing extensions and related questions (0.2) 0.80 1,850.00 1,480.00 04/04/2024 ECS1 Analyze records in connection with

preparation of estate taxes (.2); prepare

Group questions (.5); call with A. Bongartz regarding same (.1) 0.80 1,270.00 1,016.00 04/18/2024 DEB4 Correspond with L. Song regarding Kwok

04/18/2024 LS26 Review Debtor tax documents 0.90 985.00 886.50 04/19/2024 DEB4 Correspond with L. Song regarding tax documents (0.3); correspond with E. Sutton and J. Kosciewicz regarding same (0.2) 0.50 1,395.00 697.50 Subtotal: B240 Tax Issues 9.40 13,380.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 159 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00006 Invoice No. 2403070

ID Timekeeper Name Title Hours Rate Fee

AB21 Alex Bongartz Of Counsel 2.80 1,850.00 5,180.00 DEB4 Douglass E. Barron Associate 0.60 1,395.00 837.00 ECS1 Ezra C. Sutton Associate 5.10 1,270.00 6,477.00 LS26 Luyi Song Associate 0.90 985.00 886.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 160 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Genever US PH LLP Client/Matter # 50687-00010 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$116,231.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 161 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Genever US PH LLP Client/Matter # 50687-00010 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$116,231.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 162 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 12, 2024

FOR PROFESSIONAL SERVICES RENDERED for the period ending April 30, 2024

Date Initials Description Hours Rate Amount

04/04/2024 AB21 Correspond with L. Despins regarding first day declaration in Genever case (0.1);

04/04/2024 ECS1 Review Genever US docket and pleadings

Subtotal: B113 Pleadings Review 0.60 878.00

04/01/2024 AB21 Call with L. Song regarding furniture sale

04/01/2024 LS26 Call with A. Bongartz re furniture auction

04/10/2024 LS26 Call and correspond with G. Griffin re update on furniture auction 0.20 985.00 197.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 163 of 700

Date Initials Description Hours Rate Amount

04/25/2024 AB21 Correspond with L. Despins regarding sale extension (0.3); correspond with M. Cyganowski (Sales Officer) regarding same

regarding same (0.1) 0.60 1,850.00 1,110.00

process extension 0.10 1,395.00 139.50 Subtotal: B130 Asset Disposition 2.30 3,085.00

04/10/2024 AB21 Non-working travel from NY office to SN

Subtotal: B195 Non-Working Travel 0.80 740.00

04/01/2024 AB21 Correspond with H. Hardiman (Sherry Netherland) regarding W-9 form 0.10 1,850.00 185.00 04/02/2024 AB21 Correspond with J.

regarding soot remediation 0.10 1,850.00 185.00 04/03/2024 AB21 Call with M. Ullman (Sherry Netherland), S.

and D. Acheson (architect) regarding soot remediation (0.9); follow-up call with L. Despins and J. Panico regarding same (0.2) 1.10 1,850.00 2,035.00 04/03/2024 AB21 Review statement regarding proprietary rent for Sherry Netherland apartment (0.1); correspond with L. Despins regarding same 0.20 1,850.00 370.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 164 of 700

Date Initials Description Hours Rate Amount

04/03/2024 LAD4 T/c with SN officers (M. Ullman etc.), A. Bongartz, S. Millman (Hogan Lovells) and J. Panico (AAGL) re: soot remediation (.90); post-mortem with J. Panico and A.

04/04/2024 AB21 Analyze next steps with respect to SN remediation and furniture (0.3); correspond with L. Song regarding same (0.1); meeting with L. Song regarding same (0.4) 0.80 1,850.00 1,480.00 04/04/2024 LS26 Meeting with A. Bongartz re SN remediation and remediation motion 0.40 985.00 394.00 04/08/2024 AB21 Analyze soot report and related issues (0.8);

regarding status of remediation (0.1) 0.90 1,850.00 1,665.00

parts of draft remediation motion 1.30 985.00 1,280.50 04/09/2024 AB21 Correspond with J. Panico (AAGL) regarding moving furniture (0.1); call with

same (0.1); meeting with L. Song regarding motion to authorize clean-up project (1.1) 1.80 1,850.00 3,330.00 04/09/2024 LS26 Meeting with A. Bongartz re SN remediation and remediation motion (1.1);

Moving) re moving services (0.2);

apartment (0.2); correspond with G. Griffin re update on moving furniture (0.1); continue to draft remediation motion (2.1) 3.70 985.00 3,644.50 04/10/2024 AB21 Meeting with D. Acheson (architect) and Z. Barsik (DKI) regarding remediation process and soot clean-up (1.2); meeting with L. Song regarding clean-up process and related

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 165 of 700

Date Initials Description Hours Rate Amount

04/10/2024 LS26 Call and correspond with M. Fazzini

(0.1); continue to prepare draft remediation motion (1.3); conference with A. Bongartz

04/11/2024 AB21 Correspond with T. Sadler regarding wire transfer for invoice from testing company

04/11/2024 AB21 Call with L. Song regarding apartment walk through (0.1); call with S. Sebetic (potential

(0.1); call and correspond with M. Ullman (SN) regarding same (0.1); call with J.

(architect) regarding update (0.2);

04/11/2024 LS26 Call with A. Bongartz regarding Sherry Netherland apartment walkthrough (0.1); call with M. Millea (Milleas Bro.) re update

Netherland) re same (0.1); continue to draft remediation motion (2.7) 3.70 985.00 3,644.50 04/12/2024 AB21 Review proposals related to soot cleaning project (0.5); call with D. Acheson 0.90 1,850.00 1,665.00

(architect) regarding same (0.2); correspond

04/12/2024 LS26 Continue to prepare draft remediation

Sherry Netherland apartment with A. Bongartz and potential moving company 6.50 985.00 6,402.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 166 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2403072

Date Initials Description Hours Rate Amount

04/14/2024 AB21 Review proposals related to soot cleaning project (1.0); correspond with L. Despins regarding same (0.3); correspond with J. Panico (AAGL) regarding same (0.2) 1.50 1,850.00 2,775.00 04/15/2024 AB21 Revise motion to clean soot (3.0); call with L. Song regarding same (0.3); analyze next steps related to clean-up process (0.4); call with D. Acheson (architect) regarding same

regarding same (0.1); correspond with T. Sadler regarding wire transfer to architect

04/15/2024 JK21 Correspond with T. Sadler regarding wire transfer forms (0.1); prepare wire transfer form for Acheson Doyle (0.1) 0.20 565.00 113.00 04/15/2024 LS26 Call with A. Bongartz re Sherry Netherland

04/16/2024 AB21 Analyze soot cleaning and related proposals,

regarding same (0.3); correspond with J. Panico regarding same (0.1); call with L.

proposals (0.1); correspond with S. Millman regarding same (0.2); correspond with L. Despins regarding same (0.4); meeting with L. Despins regarding same (0.1); call with D. Acheson (architect) regarding same (0.2);

04/16/2024 AB21 Prepare notice of Acheson Doyle invoice

filing and service of same (0.1) 0.30 1,850.00 555.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 167 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2403072

Date Initials Description Hours Rate Amount

04/16/2024 JK21 Correspond with A. Bongartz regarding filing of notice of filing of Acheson Doyle eighth invoice (0.1); electronically file with the court notice of filing of Acheson Doyle

service of notice of filing of Acheson Doyle eighth invoice (0.1) 0.30 565.00 169.50 04/16/2024 LAD4 Review & comment on SN remediation project (1.40); t/c J. Panico (AAGL) and A. Bongartz re: soot project (.30); t/c S.

04/16/2024 LS26 Continue to review and prepare draft Sherry Netherland cleaning motion (6.1); meeting with A. Bongartz re same (0.2); correspond

04/17/2024 AB21 Continue analysis of soot cleaning project

regarding related updates (0.2); call with M.

D. Acheson, J. Panico (AAGL) and L.

with J. Panico regarding same (0.1); revise motion to authorize cleaning project (0.8); calls with L. Song regarding same (0.2); review cleaning company proposal (0.1); call

J. Pagan (Cleaning Contractors) regarding same (0.4); correspond with B. Hildebrandt (Hillmann) regarding DKI proposal (0.2);

remediation project (0.2) 3.20 1,850.00 5,920.00 04/17/2024 LAD4 Participate on call with SN officer (M. Ullman), SN counsel (S. Millman), A. Bongartz re: soot project 0.40 1,975.00 790.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 168 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2403072

Date Initials Description Hours Rate Amount 04/17/2024 LS26 Continue to prepare Sherry Netherland cleaning motion (1.1); calls with A. Bongartz re same (0.2); call and correspond with M. Fanizzi (Montvale Moving) re moving proposal (0.1) 1.40 985.00 1,379.00 04/18/2024 AB21 Revise motion to approve cleaning of SN apartment (1.1); correspond with L. Despins regarding same (0.1); revise related motion to shorten notice (0.2); call with L. Song regarding same (0.1); correspond with L. Despins regarding same (0.2); call with L. Despins regarding same (0.1); correspond with M. Ullman (SN) regarding cleaners' and mover's proposals (0.2); review related documents (0.1); call and correspond with L. Song regarding same (0.1); call with D. Acheson (architect) regarding same (0.2); call with F. Sciame (Sciame) regarding same (0.1); call with B. Hildebrandt (Hillmann) regarding DKI proposal (0.2); correspond with F. Sciame regarding same (0.1) 2.80 1,850.00 5,180.00 04/18/2024 LAD4 Review/edit SN motion to allow soot project (2.00); t/c A. Bongartz re: same (.10) 2.10 1,975.00 4,147.50 04/18/2024 LS26 Continue to draft motion to limit service and shorten notice on Sherry Netherland cleaning motion (2.1); call with A. Bongartz re same (0.1); review and correspond with moving company re proposal and certificate of insurance (0.2); call and correspond with A. Bongartz re same (0.1) 2.50 985.00 2,462.50 04/19/2024 AB21 Revise soot cleaning motion (0.3); correspond with M. McCormack (OMJB) regarding same (0.1) 0.40 1,850.00 740.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 169 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2403072

Date Initials Description Hours Rate Amount 04/22/2024 AB21 Call with B. Hildebrand (Hillmann) regarding soot cleaning proposal (0.2); call with D. Acheson (architect) regarding update on remediation project (0.3); correspond with L. Song regarding movers and warehouse proposal (0.1); correspond with L. Despins regarding update on cleaning project (0.1); review comments from M. McCormack (OMJB) regarding cleaning motion (0.1) 0.80 1,850.00 1,480.00 04/23/2024 AB21 Continue to analyze vendor proposals related to SN cleaning project (0.3); correspond with B. Hildebrand (Hillmann) regarding Hillmann proposal (0.1); correspond with G. Chomenko (GBTS) regarding GBTS proposal (0.2); analyze process for moving/cleaning furniture (0.2); call with D. Acheson (architect) regarding update on cleaning project (0.2); calls with F. Sciame (Sciame) regarding same (0.1); call with L. Song regarding same (0.1); correspond with L. Despins regarding same (0.3); correspond with M. Ullman (SN) regarding same (0.2); revise motion authorizing cleaning project (1.9); correspond with L. Despins regarding same (0.1); correspond with D. Mohamed regarding bluebook/citechecking same (0.1) 3.80 1,850.00 7,030.00 04/23/2024 LS26 Continue to draft cleaning motion re SN apartment (0.8); correspond with vendors regarding the furniture cleaning and moving 1.30 985.00 1,280.50

(0.4); call with A. Bongartz re same (0.1)

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 170 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2403072

Date Initials Description Hours Rate Amount 04/24/2024 AB21 Finalize motion to authorize cleaning project, including exhibits (1.3); conference with L. Despins regarding same (0.2); call with L. Despins regarding same (0.2); correspond with M. McCormack (OMJB) regarding same (0.2); correspond with S. Millman (Hogan Lovells) regarding same (0.1); call with L. Song regarding same (0.1); correspond with D. Acheson (architect) regarding same (0.2); call with D. Acheson regarding same (0.2); correspond with G. Chomenko (GBTS) regarding GBTS proposal (0.2); correspond with M. Bielawski (ABF) regarding ABF proposal (0.1); correspond with F. Sciame (Sciame) regarding Sciame proposal (0.1); correspond with B. Hildebrand (Hillmann) regarding Hillmann proposal (0.2); correspond with Z. Barsik (DKI) regarding DKI proposal (0.2) 3.30 1,850.00 6,105.00 04/24/2024 AB21 Call with L. Song regarding moving of furniture (0.1); correspond with M. Ullman (SN) regarding same (0.1); correspond with D. Mohamed regarding filing of motion to authorize cleaning project (0.1) 0.30 1,850.00 555.00 04/24/2024 DM26 File via the Court's CM/ECF system Genever US cleaning motion and motion to limit service of same (.4); prepare and effectuate service of same (.5) 0.90 565.00 508.50 04/24/2024 LAD4 Review/edit revised motion re: soot project (.80); meeting A. Bongartz re: same (.20); t/c A. Bongartz re: same (.20) 1.20 1,975.00 2,370.00 04/24/2024 LS26 Review Sherry Netherland cleaning motion (0.7); call with A. Bongartz re same (0.1); correspond with vendors on cleaning and moving of furniture items (0.3); call with A. Bongartz re same (0.1) 1.20 985.00 1,182.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 171 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2403072

Date Initials Description Hours Rate Amount

04/25/2024 AB21 Call with S. Millman (Hogan Lovells) regarding soot cleaning motion (0.3); call

(SN) regarding same (0.1); correspond with

notice (0.1); correspond with M.

soot cleaning motion and related order to shorten notice (0.1); correspond with D.

shorten notice (0.1) 0.80 1,850.00 1,480.00 04/25/2024 DM26 Continue to prepare and effectuate service

04/25/2024 LS26 Further correspond with vendors on cleaning and moving SN furniture (0.5); call with A. Bongartz regarding same (0.1) 0.60 985.00 591.00 04/26/2024 AB21 Call with L. Song regarding

(0.3);

regarding same (0.2) 0.90 1,850.00 1,665.00 04/26/2024 LS26 Call with A. Bongartz re cleaning and moving SN furniture (0.3); call with Light Touch re same (0.3) 0.60 985.00 591.00 04/29/2024 AB21 Review certificate of service re cleaning

remediation project (0.3); correspond with

04/29/2024 LS26 Meet with Cleaning Contractors on site re surface cleaning of furniture 0.40 985.00 394.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 172 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2403072

Date Initials Description Hours Rate Amount 04/30/2024 AB21 Finalize status report (0.1); correspond and call with D. Acheson (architect) regarding update on remediation project (0.1); correspond with S. Millman (Hogan Lovells) regarding draft report (0.1); call with Z. Bersik (DKI) regarding cleaning project (0.1); correspond with L. Song regarding same (0.1) 0.50 1,850.00 925.00 04/30/2024 AB21 Correspond with T. Sadler regarding wiring OMJB fees 0.10 1,850.00 185.00 04/30/2024 DM26 File sixth March 2024 status report re: remediation of the Sherry Netherland apartment via the Court's CM/ECF system (.2); prepare and effectuate service regarding same (.5) 0.70 565.00 395.50 04/30/2024 LS26 Meet with Cleaning Contractors on site at Sherry Netherland apartment re cleaning of furniture (0.4); correspond with Montvale Moving re packing and moving (0.1) 0.50 985.00 492.50 Subtotal: B210 Business Operations 76.20 109,924.00 B211 Financial Reports (Monthly Operating Reports) 04/03/2024 DEB4 Correspond with D. Skalka regarding MOR 0.20 1,395.00 279.00 Subtotal: B211 Financial Reports (Monthly Operating Reports) 0.20 279.00

and correspond with L. Despins 0.20 1,850.00 370.00

(0.1); call with T. Sadler regarding same

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 173 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2403072

Date Initials Description Hours Rate Amount

04/25/2024 TS21 Correspond with A. Bongartz regarding Sherry Netherland payments (.6); call with A. Bongartz regarding same (.1) 0.70 1,365.00 955.50 Subtotal: B230 Financing/Cash Collections 0.90 1,325.50

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 6.70 1,975.00 13,232.50

Bongartz Of Counsel 35.30 1,850.00 65,305.00 AB21 Alex Bongartz Of Counsel 0.80 925.00 740.00 DEB4 Douglass E. Barron Associate 0.30 1,395.00 418.50 TS21 Tess Sadler Associate 0.70 1,365.00 955.50 ECS1 Ezra C. Sutton Associate 0.40 1,270.00 508.00 LS26 Luyi Song Associate 34.00 985.00 33,490.00 JK21 Jocelyn Kuo Paralegal 0.50 565.00 282.50 DM26 David Mohamed Paralegal 2.30 565.00 1,299.50

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

PH LLP Client/Matter # 50687-00013 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$28,867.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 175 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

PH LLP Client/Matter # 50687-00013 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$28,867.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 176 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

FOR PROFESSIONAL SERVICES RENDERED for the period ending April 30, 2024 Golden Spring Adversary Proceeding \$28,867.50

Date Initials Description Hours Rate Amount

04/01/2024 LS26 Call with M. Davis (Paramount Facility

with M.

of storage units (0.4); calls and correspond with N. Bassett re same (0.5); correspond with P. Parizek (Kroll) re same (0.1) 1.50 985.00 1,477.50 04/01/2024 NAB Correspond and calls with L. Song

steps (.5); correspond with Westy counsel regarding same (.2) 0.70 1,835.00 1,284.50 04/02/2024 LS26 Call and correspond with M. Davis (Paramount Facility Management) re storing storage unit contents (0.3); correspond with M.

storage unit contents (0.3); correspond with F.

notice re accessing Mahwah mansion (0.1); correspond with N. Bassett re same (0.1); correspond with auctioneer re storage unit

Date Initials Description Hours Rate Amount

04/03/2024 ECS1 Review Golden Spring storage unit

04/03/2024 LS26 Review issues regarding and oversee move

04/04/2024 LS26 Review issues regarding and oversee move

04/05/2024 LS26 Review issues regarding and oversee moving of storage unit contents 5.00 985.00 4,925.00 04/22/2024 DEB4 Correspond with N. Bassett and L. Song

issues (0.5); analyze documents related to

04/22/2024 LS26 Correspond with N. Bassett re Golden

Spring documents (0.3) 0.60 985.00 591.00 04/24/2024 LS26 Analyze Golden Spring privilege issue 0.40 985.00 394.00 Subtotal: B191 General Litigation 23.60 24,336.50

04/03/2024 LS26 Travel from New York to storage unit in

Jersey to New York (1.4) (bill at 1/2 rate) 2.70 492.50 1,329.75

04/04/2024 LS26 Travel from New York to storage unit in

Jersey to New York (1.4) (bill at 1/2 rate) 2.70 492.50 1,329.75

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 178 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00013 Invoice No. 2403073

Date Initials Description Hours Rate Amount

04/05/2024 LS26 Travel from New York to Westy Self Storage in New Jersey (1.1); return travel

(bill at 1/2 rate) from New Jersey to New York (1.5); travel 3.80 492.50 1,871.50 Subtotal:

ID Timekeeper Name Title Hours Rate Fee NAB Nicholas A. Bassett Partner 0.70 1,835.00 1,284.50 DEB4 Douglass E. Barron Associate 1.00 1,395.00 1,395.00 ECS1 Ezra C. Sutton Associate 0.30 1,270.00 381.00 LS26 Luyi Song Associate 21.60 985.00 21,276.00 LS26 Luyi Song Associate 9.20 492.50 4,531.00

Total Balance Due - Due Upon Receipt \$28,867.50

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

HCHK Adversary Proceeding PH LLP Client/Matter # 50687-00014 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$34,106.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 180 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

HCHK Adversary Proceeding PH LLP Client/Matter # 50687-00014

Legal fees for professional services for the period ending April 30, 2024 \$34,106.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 181 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 12, 2024

FOR PROFESSIONAL SERVICES RENDERED for the period ending April 30, 2024

Date Initials Description Hours Rate Amount

04/01/2024 DEB4 Correspond with N. Bassett and P. Linsey (NPM) regarding reply in support of default

04/02/2024 NAB Analyze objection to motion for default

04/03/2024 DEB4 Correspond with P. Linsey (NPM) regarding reply brief in support of default

04/04/2024 DEB4 Correspond with P. Linsey regarding reply in support of default judgment 3.20 1,395.00 4,464.00 04/04/2024 DEB4 Conference with P. Linsey and N. Bassett

04/04/2024 NAB Further analyze opposition to motion for default judgment (.4); call with D. Barron and P. Linsey (NPM) regarding same (.6) 1.00 1,835.00 1,835.00 04/08/2024 ECS1 Correspond with N. Bassett and W. Farmer re HCHK appellee designation 0.20 1,270.00 254.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 182 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2403074

Date Initials Description Hours Rate Amount

04/08/2024 LS26 Prepare appellee counter-designation for

default (3.0); correspond with P. Linsey re

04/08/2024 NAB Review appellate designations (.2); correspond with P. Linsey (NPM) regarding

04/11/2024 DEB4 Correspond with P. Linsey (NPM)

04/11/2024 NAB Review and revise draft reply in support of motion for default judgment (1.3); review

connection with same (.4); correspond with P. Linsey (NPM) regarding same (.1) 1.80 1,835.00 3,303.00 04/12/2024 LAD4 Review/edit our reply in support of default

04/22/2024 NAB Review our briefing, prior orders, and

default judgment (.8); correspond with P.

submissions and prepare outline for hearing

04/23/2024 DEB4 Correspond with L. Song and P. Linsey (NPM) regarding hearing (0.2); correspond

documents regarding same (0.7) 1.20 1,395.00 1,674.00 04/23/2024 NAB Review issues and caselaw

default judgment motion (2.2); correspond with D. Barron regarding same (.2);

(NPM) regarding same (.3) 2.70 1,835.00 4,954.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 183 of 700

Date Initials Description Hours Rate Amount

04/25/2024 NAB Correspond with J.

counsel) regarding appeal (.1); correspond

regarding same (.1) 0.20 1,835.00 367.00 Subtotal: B191 General Litigation 20.40 32,159.00

04/03/2024 ECS1 Correspond with N. Shanahan (Cole

related invoices (.1); correspond with L.

with T. Sadler regarding same (.1) 0.30 1,270.00 381.00 04/15/2024 ECS1 Correspond with T. Sadler regarding

04/17/2024 ECS1 Prepare monthly operating report in

expenses (.3); correspond with D. Barron, L. Despins, and R. Jareck (Cole Schotz) re

04/18/2024 ECS1 Prepare monthly operating report in

04/18/2024 JK21 Correspond with E. Sutton regarding filing of HCHK assignee expense report (0.1);

electronic filing (0.1); electronically file HCHK assignee expense report (0.1) 0.30 565.00 169.50 04/19/2024 ECS1 Correspond with N. Shanahan (Cole Schotz) regarding administration of HCHK 0.10 1,270.00 127.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 184 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 4

Date Initials Description Hours Rate Amount

payment of HCHK Entities' invoices 0.10 1,270.00 127.00 Subtotal: B210 Business Operations 1.70 1,947.50

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 1.10 1,975.00 2,172.50 NAB Nicholas A. Bassett Partner 10.00 1,835.00 18,350.00 DEB4 Douglass E. Barron Associate 5.90 1,395.00 8,230.50 ECS1 Ezra C. Sutton Associate 1.60 1,270.00 2,032.00 LS26 Luyi Song Associate 3.20 985.00 3,152.00 JK21 Jocelyn Kuo Paralegal 0.30 565.00 169.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 185 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Mei Guo Adversary Proceeding PH LLP Client/Matter # 50687-00016 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$790.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 186 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Mei Guo Adversary Proceeding PH LLP Client/Matter # 50687-00016 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$790.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 187 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho

No.

Initials Description Hours Rate Amount

LAD4 Review Bombardier opinion 0.40 1,975.00 790.00 Subtotal: B191 General Litigation 0.40 790.00

Luc A. Despins Partner 0.40 1,975.00 790.00

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 188 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Lamp Capital Adversary PH LLP Client/Matter # 50687-00024 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$45,650.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 189 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Lamp Capital Adversary PH LLP Client/Matter # 50687-00024 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$45,650.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 190 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 12, 2024

FOR PROFESSIONAL SERVICES RENDERED for the period ending April 30, 2024

Date Initials Description Hours Rate Amount

04/10/2024 JK21 Correspond with N. Bassett regarding Lamp Capital appeal brief 0.10 565.00 56.50 04/14/2024 NAB Review Lamp Capital appellate brief 0.40 1,835.00 734.00 04/16/2024 NAB Analyze and comment on Lamp Capital appellate briefing 1.00 1,835.00 1,835.00 04/17/2024 DEB4 Correspond with E. Sutton regarding Lamp Capital appeal brief 0.10 1,395.00 139.50 04/19/2024 JPK1 Review briefing related to Lamp Capital appeal (2.8); review hearing transcript (1.1); draft parts of appellate brief (1.3) 5.20 1,185.00 6,162.00 04/21/2024 JPK1 Draft statement of case for Lamp Capital appellate brief 1.00 1,185.00 1,185.00 04/22/2024 JPK1 Draft statement of case sections for Lamp Capital appellate brief (5.0); draft argument sections for the same (1.4) 6.40 1,185.00 7,584.00 04/24/2024 JPK1 Attend teleconference with N. Bassett and W.

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 191 of 700 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00024 Invoice No. 2403077

Date Initials Description Hours Rate Amount

04/24/2024 JPK1 Draft willfulness argument for Lamp Capital appellate brief (3.9); analyze caselaw regarding the same (2.9) 6.80 1,185.00 8,058.00 04/24/2024 NAB Analyze appellate arguments and review appellee brief (.6); call with J. Kosciewicz and W. Farmer regarding same (.5) 1.10 1,835.00 2,018.50 04/24/2024 WCF Call with J. Kosciewicz and N. Bassett regarding Lamp Capital appellate brief 0.50 1,390.00 695.00 04/26/2024 JPK1 Draft argument section regarding

Capital appellate brief (4.1); analyze case law regarding the same (2.7) 6.80 1,185.00 8,058.00 04/27/2024 JPK1 Draft prejudice argument for Lamp Capital

regarding Appellants' argument related to willfulness (1.3) 3.80 1,185.00 4,503.00 04/28/2024 JPK1 Draft preliminary statement for Lamp Capital Appellate brief 1.50 1,185.00 1,777.50 04/29/2024 JPK1 Review and revise Lamp Capital appellate

04/30/2024 JPK1 Review G Club response to appellate brief 0.30 1,185.00 355.50 Subtotal: B191 General Litigation 37.10 45,650.00

ID Timekeeper Name Title Hours Rate Fee

NAB Nicholas A. Bassett Partner 2.50 1,835.00 4,587.50 DEB4 Douglass E. Barron Associate 0.10 1,395.00 139.50 WCF Will C. Farmer Associate 0.50 1,390.00 695.00 JPK1 Jon P. Kosciewicz Associate 33.90 1,185.00 40,171.50 JK21 Jocelyn Kuo Paralegal 0.10 565.00 56.50 Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 192 of 700

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00024 Invoice No. 2403077 Page 3

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

PH LLP Client/Matter # 50687-00026 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$26,323.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

PH LLP Client/Matter # 50687-00026 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$26,323.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 195 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of

FOR PROFESSIONAL SERVICES RENDERED for the period ending April 30, 2024 Ace Decade Adversary Proceeding \$26,323.50

Date Initials Description Hours Rate Amount

04/05/2024 JPK1 Correspond with D. Mohamed regarding filing deadline for response to Y. Wang's motion to extend time to interpose answer 0.20 1,185.00 237.00 04/05/2024 NAB Correspond with J. Kosciewicz regarding

04/06/2024 JPK1 Draft parts of response to Y. Wang's

answer (1.4); analyze caselaw and statutory authority regarding the same (1.6) 3.00 1,185.00 3,555.00 04/07/2024 JPK1 Analyze authority regarding proceeding

defendant has not been served 2.00 1,185.00 2,370.00 04/08/2024 JPK1 Analyze "necessary party" for avoidable

opposition to extend time (3.3); correspond with N. Bassett regarding the same (.2) 4.60 1,185.00 5,451.00 04/08/2024 NAB Correspond with J. Kosciewicz regarding draft response to motion to extend time 0.20 1,835.00 367.00

Date Initials Description Hours Rate Amount

04/09/2024 AB21 Review order denying motion to extend

04/09/2024 NAB Correspond with J. Kosciewicz regarding response to motion to extend time (.1);

decision on motion to extend time (.2) 0.50 1,835.00 917.50 04/12/2024 AB21 Review Y. Wang's motion to reconsider

04/12/2024 JPK1 Review Y. Wang's motion to reconsider

interpose an answer 0.30 1,185.00 355.50 04/12/2024 LAD4 Review Wang's motion for reconsideration 0.30 1,975.00 592.50 04/12/2024 NAB Review Y. Wang's motion for reconsideration (.2); correspond with L. Despins regarding same (.1) 0.30 1,835.00 550.50 04/15/2024 NAB Telephone conference with Y. Wang

04/16/2024 LS26 Call and correspond with P. Linsey (NPM)

04/18/2024 AB21 Correspond with M. Meili (Prager) regarding service on Rui Hao (0.2);

International) regarding same (0.1) 0.30 1,850.00 555.00 04/19/2024 AB21 Correspond with M. Meili (Prager) regarding service on Rui Hao in Switzerland (0.1); correspond with E. Ring (Ancillary) regarding same (0.1) 0.20 1,850.00 370.00 04/21/2024 NAB Correspond with A. Bongartz regarding Y. Wang motion for reconsideration (.1); review motion in connection with same (.3) 0.40 1,835.00 734.00 04/22/2024 NAB Correspond with L. Despins regarding litigation strategy 0.20 1,835.00 367.00 04/25/2024 DEB4 Correspond with J. Kosciewicz regarding

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 197 of 700

04/26/2024 AB21 Correspond with D. Barron regarding default as against Ace Decade 1,850.00 185.00

default judgment against Ace Decade 0.10 1,185.00 118.50

regarding default notice 0.10 1,395.00 139.50

Draft opposition to Defendant Wang's Rule

statutory authority regarding the same (1.1);

opposition (.5) 6.60 1,185.00 7,821.00 Subtotal: B191 General Litigation 20.50 26,323.50

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 0.30 1,975.00 592.50 NAB Nicholas A. Bassett Partner 2.00 1,835.00 3,670.00 AB21 Alex Bongartz Of Counsel 0.80 1,850.00 1,480.00 DEB4 Douglass E. Barron Associate 0.20 1,395.00 279.00 JPK1 Jon P. Kosciewicz Associate 16.80 1,185.00 19,908.00 LS26 Luyi Song Associate 0.40 985.00 394.00

Total Balance Due - Due Upon Receipt \$26,323.50

Case 22-50073 Doc 3700 Filed 10/15/24 Entered 10/15/24 19:17:45 Page 198 of 700

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

CAO Adversary Proceeding PH LLP Client/Matter # 50687-00027 Luc A. Despins

Legal fees for professional services for the period ending April 30, 2024 \$21,011.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*