Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3701

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

| ------------------------------------------------------ | x | | |--------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, et al., | :<br>: | Case No. 22-50073 (JAM) | | Debtors.1 | :<br>:<br>: | Jointly Administered | | ------------------------------------------------------ | x | |

# **APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF JAMES MORGAN AS BARRISTER IN BRITISH VIRGIN ISLANDS**

Mr. Luc A. Despins, in his capacity as the Chapter 11 Trustee (the "Chapter 11 Trustee") appointed in the above-captioned chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok (the "Debtor"), pursuant to sections 327, 328, and 330 of Title 11 of the United States Code (the "Bankruptcy Code"), Rules 2014 and 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rules 2014-1 and 2016-1 of the Local Rules of Bankruptcy Procedure (the "Local Bankruptcy Rules") for the United States Bankruptcy Court for the District of Connecticut (the "Court"), files this application (the "Application") requesting entry of an order, substantially in the form attached hereto as **Exhibit A** (the "Proposed Order") authorizing his employment of Mr. James Morgan, King's Counsel ("Mr. Morgan"), as barrister in the British Virgin Islands ("BVI") under the instruction of Harney Westwood & Riegels LP ("Harneys"). In

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).

support of this Application, the Chapter 11 Trustee submits the *Declaration of James Morgan in Support of Application of Chapter 11 Trustee for Entry of Order, Pursuant to Bankruptcy Code Sections 327, 328, and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Authorizing and Approving Retention and Employment of James Morgan as Barrister in British Virgin Islands* (the "Morgan Declaration"), attached as **Exhibit B**, which is incorporated herein by reference. In further support of this Application, the Chapter 11 Trustee states the following:

## **RELIEF REQUESTED**

1. By this Application, the Chapter 11 Trustee seeks entry of an order, substantially in the form of the proposed order filed herewith (the "Proposed Order"), authorizing and approving the retention and employment of James Morgan, King's Counsel as the Chapter 11 Trustee's barrister in the BVI, effective as of September 16, 2024, to act as barrister under the instruction of Harneys in connection with the Trustee litigation in the BVI courts to that, among other things, shares of K Legacy Ltd ("K Legacy") and the London apartment purportedly owned by K Legacy are property of the estate (the "K Legacy Action") and related matters.

2. The Chapter 11 Trustee selected James Morgan as his barrister based on his expertise in corporate and commercial litigation in the BVI, as well as his extensive experience in complex commercial matters under BVI law.

## **JURISDICTION, VENUE, AND STATUTORY BASES**

3. 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 is a core proceeding within the meaning of 28 U.S.C. § 157(b).

4. Venue in this District is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

5. The statutory bases for the relief requested herein are sections 327(a), 328(a), and 330 of the Bankruptcy Code, and, to the extent applicable, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1.

## **BACKGROUND**

6. On February 15, 2022 (the "Petition Date"), the Debtor filed with the Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

7. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Debtor's Chapter 11 Case.

8. 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. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Chapter 11 Trustee [Docket No. 514].

9. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Chapter 11 Trustee in the Chapter 11 Case [Docket No. 523].

## **QUALIFICATIONS**

10. James Morgan is a highly regarded commercial practitioner in the BVI, with particular expertise in the fields of restructuring and insolvency, as well as company and commercial dispute resolution. He has a wealth of trial experience and considerable expertise in applications for interim relief, including freezing orders and injunctions. Mr. Morgan is called to the Bar of the Eastern Caribbean Supreme Court, British Virgin Islands, and is experienced in dealing with cross-border issues in commercial and insolvency litigation.

## **ANTICIPATED SERVICES**

11. The Chapter 11 Trustee anticipates that Mr. Morgan will serve as his barrister in the BVI with respect to all matters related to the K Legacy Action. Due to the specialized nature of the role of a barrister, there will be no duplication of services arising from his retention, including in connection with Harneys, who serve as the Trustee's counsel in the BVI, and from whom Mr. Morgan will receive instruction.

## **COMPENSATION OF MR. MORGAN**

12. Mr. Morgan intends to apply to the Court for compensation for professional services rendered and for reimbursement of expenses incurred in connection with this Chapter 11 Case pursuant to sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, Local Bankruptcy Rule 2016-1, and any other applicable rules and orders with respect to this Chapter 11 Case. Mr. Morgan will charge the Debtor for his legal services on an hourly basis at his regularly applicable hourly rates in connection with barrister's services required in the K Legacy Action.

13. At present, Mr. Morgan's 2024 hourly rate for this type of work is £800. Mr. Morgan will also bill for out-of-pocket expenses made on behalf of the Debtor, including photocopying, postage and package deliveries, court fees, transcripts, witness fees, service fees, travel expenses, and computer-aided research.

14. The Debtor submits that Mr. Morgan's hourly rates are reasonable, comparable to his hourly rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.

## **MR. MORGAN IS DISINTERESTED**

15. To the best of the Chapter 11 Trustee's knowledge in reliance upon the Morgan Declaration, and except as disclosed therein, Mr. Morgan does not have any relationships with the Debtor, its creditors, or any other party-in-interest, their respective attorneys and accountants, the United States Trustee, or any person employed in the Office of the United States Trustee.

16. More specifically, upon the basis of the Morgan Declaration, and except as disclosed therein, the Chapter 11 Trustee believes that: (a) Mr. Morgan has no connection with the Debtor, his creditors, the U.S. Trustee, any person employed in the office of the U.S. Trustee, or any other party with an actual or potential interest in the Debtor or his respective attorneys or accountants; and (b) Mr. Morgan (i) is not a creditor, equity security holder, or insider of the Debtor or his affiliates, (ii) has not been, within two years before the Petition Date, a director, officer, or employee of the Debtor or his affiliates, and (iii) has not had any interest materially adverse to the interests of the Debtor's estate or any class of creditors or equity security holders by reason of any direct or indirect relationship to, connection with, or interest in the Debtor, or for any other reason. Therefore, the Chapter 11 Trustee believes that Mr. Morgan is a "disinterested person" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).

17. Based on the Morgan Declaration, the Chapter 11 Trustee believes that Mr. Morgan does not represent any adverse interest to unsecured creditors in connection with the Chapter 11 Case.

## **BASIS FOR RELIEF REQUESTED**

18. The Chapter 11 Trustee requests to retain and employ Mr. Morgan as his barrister in the BVI with respect to the K Legacy Action pursuant to section 327(a) of the Bankruptcy

Code, which provides that a trustee, subject to the approval of the Court, may employ

professional persons "that do not hold or represent an interest adverse to the estate, and that are disinterested persons, to represent or assist the trustee in carrying out the trustee's duties under this title."

19. 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).

20. Bankruptcy Rule 2014(a) provides that an application for retention include:

specific facts showing the necessity for the employment, the name of the [firm] to be employed, the reasons for the selection, the professional services to be rendered, any proposed arrangement for compensation, and, to the best of the applicant's knowledge, all of the [firm's] connections with the debtor, creditors, any other party in interest, their respective attorneys and accountants, the United States trustee.

21. The Chapter 11 Trustee requires the services of a specialist King's Counsel in BVI proceedings to opine and assist in the recovery of the luxury apartment in London (which is nominally owned by K Legacy) for the benefit of the estate. While this Court has previously entered a default judgment against K Legacy and the Debtor's son, i.e., Qiang Guo, holding that K Legacy and the apartment are property of the estate, *see* Docket No. 76 in Adv. Proc. No. 24- 5249, in order to be able to recover the property in the United Kingdom, the Trustee must also seek relief in the BVI, i.e., the jurisdiction where K Legacy is incorporated, to establish the estate ownership of K Legacy and the property. These efforts require very specialized cross-border and insolvency law expertise and Mr. Morgan is a recognized expert in that field. While Harneys is the law firm acting as the Trustee's counsel in connection with the proceedings in the BVI, the Trustee will also require a BVI-admitted silk lawyer to represent the Trustee before the BVI

courts. Mr. Morgan will endeavor to avoid the duplication of efforts and provide services as efficiently as possible.

22. Accordingly, the employment of Mr. Morgan as the Chapter 11 Trustee's barrister, upon the terms set forth herein and in the Proposed Order, is reasonable and in the best interest of the Debtor's estate.

23. The Chapter 11 Trustee submits that Mr. Morgan's rates are reasonable, comparable to rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.

24. Local Bankruptcy Rule 2014-1 provides that if "an application to employ a professional is filed within thirty (30) days after the commencement of services provided by that professional, the application shall be deemed contemporaneously filed unless the Court orders otherwise." Accordingly, the Chapter 11 Trustee requests authority to retain and employ Mr. Morgan effective September 16, 2024, which was the date that he began providing services to the Chapter 11 Trustee.

## **NOTICE**

25. Notice of this Application has been given to the United States Trustee, the Debtor, the Committee, and, by electronic filing utilizing the Court's electronic filing ("CM/ECF") system, to all appearing parties who utilize the CM/ECF system.

## **NO PRIOR REQUEST**

26. No previous application for the relief requested herein has been made to this or any other Court.

[*Remainder of page intentionally left blank.*]

## **CONCLUSION**

WHEREFORE, for the foregoing reasons, Luc A. Despins, the Chapter 11 Trustee,

requests that the Court enter an Order, substantially in the form of the Proposed Order filed herewith, granting the Application, and authorizing the Chapter 11 Trustee's employment of Mr. Morgan, as his barrister, and order such other and further relief as the Court deems just and proper.

Dated: October 15, 2024 Chapter 11 Trustee in Chapter 11 Case of Ho Wan Kwok

> */s/ Luc A. Despins* Luc A. Despins

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

| ------------------------------------------------------ | x | | |---------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, et al.,1 | :<br>: | Case No. 22-50073 (JAM) | | Debtors. | :<br>:<br>: | (Jointly Administered) | | ------------------------------------------------------x | | |

## **CERTIFICATE OF SERVICE**

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. Parties may access this filing through the Court's CM/ECF system.

Dated: October 15, 2024 New York, New York

> 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 Chapter 11 Trustee*

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).

Case 22-50073 Doc 3701 Filed 10/15/24 Entered 10/15/24 19:29:14 Page 10 of 32

# **EXHIBIT A**

**Proposed Order**

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

| ------------------------------------------------------ | x | | |--------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, et al., | :<br>: | Case No. 22-50073 (JAM) | | Debtors.1 | :<br>:<br>: | Jointly Administered | | ------------------------------------------------------ | x | |

# **[PROPOSED] ORDER (A) GRANTING APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF JAMES MORGAN AS BARRISTER IN BRITISH VIRGIN ISLANDS**

Upon the application (the "Application")2 of Chapter 11 Trustee Luc A. Despins (the "Chapter 11 Trustee") in the above-captioned chapter 11 case (the "Chapter 11 Case"), for authority to retain and employ Mr. James Morgan, King's Counsel ("Mr. Morgan"), as barrister in the British Virgin Islands (the "BVI"), effective as of September 16, 2024, pursuant to sections 327, 328, and 330 of title 11 of the United States Code (the "Bankruptcy Code"), Rules 2014 and 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rules 2014-1 and 2016-1 of the Local Rules of Bankruptcy Procedure for the United States Bankruptcy Court for the District of Connecticut (the "Local Bankruptcy Rules"), all as more fully set forth in the Application; and upon consideration of the Application and the Morgan

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

² Capitalized terms used but not otherwise defined have the meanings set forth in the Application or the Morgan Declaration.

Declaration; and this Court having jurisdiction to consider the Application and the relief requested therein in accordance with 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut; and consideration of the Application and the relief requested therein being a core proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court having found that (i) the relief requested in the Application is in the best interest of the Debtor's estate, its creditors, and all parties-in-interest, (ii) the legal and factual bases set forth in the Application and the Morgan Declaration, and the record of any hearing on the Application before this Court establish just cause for the relief granted herein, (iii) Mr. Morgan is a "disinterested person," as defined in section 101(14) of the Bankruptcy Code and as required by section 327(a) of the Bankruptcy Code, and (iv) Mr. Morgan does not hold or represent an interest adverse to the Debtor's estate; and due and sufficient notice of the Application having been given under the particular circumstances; and it appearing that no other or further notice need be given; and a hearing having been held before this Court on \_\_\_\_\_\_\_, 2024; and upon all of the proceedings had before this Court; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED THAT:

1. The Application is granted as set forth herein.

2. The Chapter 11 Trustee is authorized to retain and employ Mr. Morgan as his barrister in the BVI effective as of September 16, 2024 on the terms set forth in the Application and the Morgan Declaration.

3. Mr. Morgan is authorized to act as the Chapter 11 Trustee's barrister, and to perform those services described in the Application.

4. The Estate shall be responsible for Mr. Morgan's compensation and reimbursement of expenses with respect to the engagement.

5. The allowance of any compensation to be paid to Mr. Morgan shall be determined in accordance with the procedures set forth in sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Bankruptcy Rule 2016-1.

6. Allowance of any compensation for Mr. Morgan shall be limited to the extent of services actually performed, and expenses actually incurred, as barrister for the Chapter 11 Trustee Luc A. Despins, and shall not include compensation for the performance of any of the trustee duties that are generally performed by a Chapter 11 trustee without the assistance of a barrister.

7. Mr. Morgan shall provide no less than ten business days' notice to the Chapter 11 Trustee, the United States Trustee, and counsel to any official committee before any increases in the rate he charges are implemented and shall file such notice with the Court.

8. The Chapter 11 Trustee is authorized and empowered to take all actions necessary to effectuate the relief granted in this Order.

9. The requirements of the Local Bankruptcy Rules are satisfied by the contents of the Application.

10. To the extent the Application and Morgan Declaration are inconsistent with this Order, the terms of this Order shall govern.

11. The terms and conditions of this Order shall be immediately effective and enforceable upon its entry.

12. This Court shall retain jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order.

Case 22-50073 Doc 3701 Filed 10/15/24 Entered 10/15/24 19:29:14 Page 14 of 32

## **EXHIBIT B**

**Morgan Declaration**

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

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|--------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, et al., | :<br>: | Case No. 22-50073 (JAM) | | Debtors.1 | :<br>: | Jointly Administered | | ----------------------------------------------------------- | :<br>x | |

# **DECLARATION OF JAMES MORGAN IN SUPPORT OF APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF JAMES MORGAN AS BARRISTER IN BRITISH VIRGIN ISLANDS**

I, James Morgan, being duly sworn, do depose and say:

1. I am a qualified King's Counsel and enrolled before the Bar of the Eastern

Caribbean Supreme Court, British Virgin Islands as a barrister, and I also sit in London as a

Deputy High Court Judge (Chancery) and as a Recorder of the County Court. I am a barrister at

Radcliffe Chambers, which maintains its principal office at 11 New Square, Lincoln's Inn,

London WC2A 3QB, United Kingdom, and I make this declaration (the "Declaration") in

support of the *Application of Chapter 11 Trustee for Entry of Order, Pursuant to Bankruptcy*

*Code Sections 327, 328, and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules*

*2014-1 and 2016-1, Authorizing and Approving Retention and Employment of James Morgan as*

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).

*Barrister in British Virgin Islands* (the "Application")² in connection with the K Legacy Action, and related matters (the "Engagement").

2. In relation to the Engagement, my professional client is the estate (the "Estate") of Ho Wan Kwok (the "Debtor") in his above-captioned chapter 11 case (the "Chapter 11 Case"). In relation to the Engagement, I will seek to recover my fees from the Estate, and I will file fee applications in the Chapter 11 Case.

3. I graduated in Law at Jesus College, Cambridge University in 1995 and was called to the English Bar in 1996. I am a member of Inner Temple and professional organisations including the Chancery Bar Association, R3 and IWIRC. I was featured as a leader in my fields of expertise by both *Chambers UK Bar* and The *Legal 500 UK Bar*. I deal with the fields of restructuring and insolvency, as well as company and commercial dispute resolution, and have extensive trial experience and considerable expertise in applications for interim relief, including freezing orders and injunctions.

4. I will file applications for compensation of professional services rendered and for reimbursement of expenses incurred in connection with the Engagement pursuant to sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, Local Bankruptcy Rule 2016-1, and any other applicable rules and orders with respect to this Chapter 11 Case.

5. I will charge my hourly billing rates in connection with the Engagement. At present, my 2024 hourly rate for this type of work is £800. I may also bill the Estate for any outof-pocket expenses made on behalf of the Chapter 11 Trustee, including photocopying, postage and package deliveries, court fees, transcripts, witness fees, service fees, travel expenses, and computer-aided research.

² Capitalized terms used but not otherwise defined have the meanings set forth in the Application.

6. To the best of my knowledge and belief after due inquiry, I am a "disinterested person" within the meaning of section 101(14) of title 11 of the United States Code (the "Bankruptcy Code") in that I:

- a. am not a creditor, equity security holder, or insider of the Debtor; - b. am not, and was not within two years before the date of filing of the Debtor's petition, a director, officer, or employee of the Debtor; and - c. do not have an interest materially adverse to the interest of the Debtor's estate or of any class of creditors or equity security holders, by reason of any direct or indirect relationship to, connection with, or interest in, the Debtor, or for any other reason.

7. I attach to this Declaration, as Schedule 1, a consolidated list of parties in interest in connection with the Chapter 11 Case (the "Interested Parties") that has been produced by Paul Hastings and provided to me before my signing this Declaration that I am informed includes:

- a. parties listed as creditors, executory contract counterparties, and codebtors on the Debtor's Schedules D, F, G, and H [Docket No. 78]; - b. parties listed on the Debtor's Statement of Financial Affairs ("SOFA") [Docket No. 77], including (i) as recipients of payments within 90 days prior to the filing of the Chapter 11 Case (SOFA Part 3, Question 6); (ii) parties involved in litigation in which the Debtor is a party (SOFA Part 4, Question 9); - c. businesses owned by the Debtor (SOFA Part 11, Question 27); - d. parties and counsel filing notice of appearances in the Chapter 11 Case; - e. the Court and personnel of the office of the United States Trustee; and

f. other parties in interest that I have become aware of as a result of the Chapter 11 Trustee's ongoing investigation of the Debtor's assets.

I have conducted reasonable checks of the Interested Parties against my records and data, and have determined that to the best of my knowledge and belief, I do not have any relationship or connection with the Largest Unsecured Creditors, the Debtor, Family Members and Related Entities, the Bankruptcy Judge and U.S. Trustee Personnel. To the best of my knowledge, I do not have any relationship or connection with the Other Interested Parties, or, to the best of my knowledge, with any other creditor of the Debtor.

8. While I have made a diligent effort to ascertain the identity of any connections or potential conflicts with the Interested Parties, to the extent that any additional information comes to light, I will review, disclose, and resolve any conflict or adverse interests that may appear.

9. Based on the foregoing, insofar as I have been able to ascertain based on the information currently available to me: (a) I have no connection with the Debtor, his creditors, the U.S. Trustee, any person employed in the office of the U.S. Trustee, or any other party with an actual or potential interest in the Debtor or his respective attorneys or accountants; and (b) (i) I am not a creditor, equity security holder, or insider of the Debtor or his affiliates, (ii) I have not been, within two years before the Petition Date, a director, officer, or employee of the Debtor or his affiliates, and (iii) I do not have any interest materially adverse to the interests of the Debtor's estate or any class of creditors or equity security holders by reason of any direct or indirect relationship to, connection with, or interest in the Debtor, or for any other reason. Therefore, I understand from information provided to me by Paul Hastings that this means I am a "disinterested person" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).

10. I further understand from such information that Appendix B of the U.S. Trustee

Guidelines (the "Larger Case Guidelines") does not apply in this Chapter 11 Case, because the

Debtor's petition does not list \$50 million or more in assets and \$50 million or more in liabilities.

In particular, I am informed that the Debtor estimated the value of his assets between \$50,001

and \$100,000.

11. In the interest of providing maximum disclosure, and notwithstanding my position

concerning the inapplicability of the Larger Case Guidelines, I provide the following response to

the request for information set forth in Paragraph D.1. of the Larger Case Guidelines:

Question: Did you agree to any variations from, or alternatives to, your standard or customary billing arrangements for this engagement?

- Answer: No. - Question: Do any of the professionals included in this engagement vary their rate based on the geographic location of the bankruptcy case? - Answer: No. - Question: If you represented the client in the 12 months prepetition, disclose your billing rates and material financial terms for the prepetition engagement, including any adjustments during the 12 months prepetition. If your billing rates and material financial terms have changed postpetition, explain the difference and the reasons for the difference. - Answer: Not applicable. I have not previously represented the Chapter 11 Trustee. - Question: Has your client approved your prospective budget and staffing plan, and, if so, for what budget period? - Answer: Not applicable.

12. I have neither shared nor agreed to share with any other person compensation received in connection with the Engagement, except as is permitted by §504(b)(1) of the Bankruptcy Code.

13. I consent that the following language may be included in any order by the Court approving the Chapter 11 Trustee's application in connection with my instruction in connection with the Engagement.

> Allowance of any compensation for Mr. Morgan shall be limited to the extent of services actually performed, and expenses actually incurred, as barrister instructed to act on behalf of the Chapter 11 Trustee Luc A. Despins, and shall not include compensation for the performance of any of the trustee duties that are generally performed by a Chapter 11 trustee without the assistance of a barrister.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury under the laws of the

United States that the above statements are true and correct.

Dated: October 14, 2024, at London, United Kingdom

James Morgan

## **Schedule 1**

### **SCHEDULE OF PARTIES IN INTEREST – IN RE KWOK**

### **20 LARGEST UNSECURED CREDITORS**

PACIFIC ALLIANCE ASIA OPPORTUNITY GOLDEN SPRING NEW YORK RUI MA CHENG JIAN WU JIAN SHE NING YE GUO BAOSHENG YAN LAN & WU ZHENG HONG QI QU NAN TONG SI JIAN JIAN GONG YAN ZHAO YUA HUA ZHUANG SHI LIEHONG ZHUANG/XIAO YAN ZHU WEICAN MENG/BOXUN INC. SAMUEL NUNBERG LAMP CAPITAL LLC JUN CHEN AKA JONATHAN HO YUE HUA ZHU SHI XIONG XIAN WEI YE HUIZEN WANG

### **DEBTOR, FAMILY MEMBERS, AND CERTAIN RELATED ENTITIES**

HO WAN KWOK (A.K.A MILES GWOK, MILES GUO AND WENGUI GUO) HING CH NGOK/YUE QINGZHI QIANG GUO (A.K.A. MILESON GUO) MEI GUO/MEI GUI HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC BRAVO LUCK LIMITED GENEVER HOLDINGS CORPORATION GENEVER HOLDINGS LLC

#### **BANKRUPTCY JUDGE AND U.S. TRUSTEE PERSONNEL**

HONORABLE JULIE A. MANNING WILLIAM HARRINGTON KIM L. MCCABE HOLLEY CLAIBORN JOSEPH H. FLAMINI ERIN HOGAN STEVEN MACKEY FRANK MARINO JENNIFER J. MOREY NICOLE NEELY SHARON WARNER JOHN GERVAIS

#### **OTHER INTERESTED PARTIES**

1245 FACTORY PLACE, LLC 12476517 CANADA SOCIETY 1322089 B.C. LTD. 1332156 B.C. LTD 17 MILES, LLC 2 B PACKING LLC 270 W. 39TH ST. CO., LLC 2LAWRENCE RIVER 3 COLUMBUS CIRCLE LLC 5780 SAGUARO LLC 7 NOD HILL LLC, 7 STAR EAST NY LLC 9 EAST 40TH STREET LLC A.Z. BIGIOTTERIE S.A.S. DI ZANUTTO GABRIELE & C. AAGV LIMITED AARON A. MITCHELL AARON A. ROMNEY ABRAMS FENSTERMAN, LLP ACA CAPITAL GROUP LIMITED ACA CAPITAL LIMITED ACA INVESTMENT FUND ACA INVESTMENT MANAGEMENT LTD. ACASS CANADA LTD. ACE DECADE HOLDINGS LIMITED ADAM CHEN NI AFFILIATED ADJUSTMENT GROUP, LTD. AGORA LAB, INC. AI GROUP HOLDINGS INC., AIG PROPERTY CASUALTY COMPANY AKERMAN LLP ALEX HADJICHARALAMBOUS ALFA GLOBAL VENTURES LIMITED ALFONSO GLOBAL LIMITED ALFONSO GLOBAL VENTURES LIMITED ALLIED CAPITAL GLOBAL LIMITED ALPINE FIDUCIARIES SA AMAZING SKY AVIATION LIMITED AMAZON WEB SERVICES LLC AMAZON WEB SERVICES, INC. AMAZON.COM INC. AMERICAN ARBITRATION ASSOCIATION, INC. AMERICAN EXPRESS COMPANY AMY BUCK AN HONG ANA C. IZQUIERDO-HENN ANDREW CHILDE ANDREW SULNER/FORENSIC DOCUMENT EXAMINATIONS, LLC ANN MARIE LEE ANTHEM HEALTH PLANS, INC. ANTHONY DIBATTISTA ANTON DEVELOPMENT LIMITED APPLE INC. APPSFLYER INC

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