Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3702

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., : :

Debtors1 :

----------------------------------------------------------- x **COVERSHEET RE: SIXTH INTERIM APPLICATION OF NEUBERT, PEPE & MONTEITH, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES AS LOCAL AND CONFLICTS COUNSEL TO THE CHAPTER 11 TRUSTEE AND AS COUNSEL TO DEBTORS GENEVER HOLDINGS CORPORATION AND GENEVER HOLDINGS LLC**

Time Period: May 1, 2024 through August 31, 2024

Bankruptcy Petition Filed: February 15, 2022

Date of Entry of Ret'n Orders: (i) Aug. 2, 2022 [ECF No. 669] (Kwok), effective a/o July 8, 2022, (ii) Nov. 17, 2022 [ECF No. 1107] (Genever Holdings Corp.), effective a/o Oct. 11, 2022; and (iii) Nov. 30, 2022 [ECF No. 1177] (Genever Holdings LLC), effective a/o Nov. 3, 2022.

Fees: \$1,274,303.00 Voluntary Fee Reductions: \$20,000.00 Expenses: \$23,054.71 Fees After Vol. Reductions: \$1,254,303.00

after Copies page cost: \$0.15/page \$0.00 total

Fees Previously Requested: Expense Detail:

Requested Fees: \$3,599,724.50 Retainer Received: \$0.00

Awarded Fees: \$3,579,541.50 Prior award applied: \$0.00 Paid Fees: \$3,306,776.702 Balance before this request: \$ 0.00

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

2 In addition, NPM has been paid: (a) \$446,533.20 as 80% of its fees and 100% of its expenses for the months of May and June 2024 pursuant to the May 1, 2024, through June 30, 2024 Monthly Fee Statements; and (b) Hours and Rates per professional:

Kinsella 12/1991 Counsel 110.2 \$475.00 \$52,345.00 8 Douglas S. Skalka 10/1985 Partner 133.1 \$550.00 \$73,205.00 19 Dennis M. Carnelli 11/2013 Partner 214.3 \$480.00 \$102,864.00 20 Robert B. Flynn 08/1995 Partner 219.6 \$500.00 \$109,800.00 41 Patrick R. Linsey 11/2010 Partner 860.3 \$495.00 \$425,848.50 82 James C. Graham 11/1984 Partner 248.8 \$495.00 \$123,156.00 72 William C. Sherman 11/2010 Partner 55.1 \$480.00 \$26,448.00

Jones N/A Paralegal 32.4 \$220.00 \$7,128.00 54 Sarah N. Smeriglio 11/2022 Associate 207.4 \$355.00 \$73,626.00

A. Mitchell 06/2016 Counsel 533.9 \$425.00 \$226,907.50 28 Lauren T. Astone 11/2021 Associate 12.3 \$355.00 \$4,366.50

Ahumada N/A Paralegal 152.6 \$200.00 \$30,520.00 80 Kalia Coleman N/A Law Clerk 1.1 \$200.00 \$220.00

Pierce N/A Paralegal 78.7 \$225.00 \$17,707.50 92 Lori A. Aiello N/A Paralegal 0.8 \$200.00 \$150.00

Total Hours: 2,860.6 Total Fees: \$1,274,303.00 (before \$20,000.00 discount) Blended Hourly Rate: \$445.47

\$241,491.20 as 80% of its fees and 100% of its expenses for the month of July, 2024 pursuant to its July Monthly Fee Statement. UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, :

Debtor. :

**SIXTH INTERIM APPLICATION OF NEUBERT, PEPE & MONTEITH, P.C., AS LOCAL AND CONFLICTS COUNSEL TO THE CHAPTER 11 TRUSTEE AND AS COUNSEL TO DEBTORS GENEVER HOLDINGS CORPORATION AND GENEVER HOLDINGS LLC FOR ALLOWANCE OF FEES AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM MAY 1, 2024 THROUGH AUGUST 31, 2024**

Pursuant to Sections 105(a), 328, 330, and 331 of title 11 of the United States Code (the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and 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 [ECF No. 2094] (the "Interim Compensation Procedures Order"), Neubert, Pepe and Monteith, P.C. ("NPM" or "Applicant"), as local and conflicts counsel to Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok (the "Individual Debtor"), and as counsel to the Debtors, Genever Holdings Corporation ("Genever (BVI)") and Genever Holdings LLC ("Genever (US)") in their chapter 11 cases (together with the "Chapter 11 Case," collectively, the "Chapter 11 Cases"), hereby files this *Sixth Interim Application of Neubert, Pepe and Monteith, P.C., as Local and Conflicts Counsel to the Chapter 11 Trustee and as Counsel to Debtors Genever Holdings Corporation and Genever Holdings LLC, for Allowance of Fees and Reimbursement Expenses for* the Period from May 1, 2024 through August 31, 2024 (the "Application"). By this Application, NPM \requests interim allowance of professional fees and reimbursement of expenses incurred during the period from May 1, 2024, through and including August 31, 2024 (the "Application Period") in these Chapter 11 Cases. In support hereof, NPM respectfully states as follows: JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

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

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

3. NPM believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, and the *United States Trustee's Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases* (the "U.S. Trustee Guidelines").[1] NPM respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 4. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains the Proposed Order granting this Application. - Exhibit B contains a summary of work performed and fees incurred organized by category.

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

- Exhibit C contains a summary of expense reimbursement requested organized by nature of the expenses. - Exhibit D contains a summary of work performed and fees incurred organized by the Specific Avoidance Action. - Exhibit E contains time entries with respect to the legal services provided organized by category (as discussed below). - Exhibit F contains expense reimbursements requested.

I. The Individual Debtor's Chapter 11 Case

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

6. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Chapter 11 Case. No examiner has been appointed in the Chapter 11 Case.

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

8. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the Chapter 11 Case of Ho Wan Kwok.

9. By order entered August 2, 2022, the Court authorized NPM's retention as local and conflicts counsel for the Trustee [ECF No. 669] (the "Retention Order") effective as of July 8, 2022, in the Chapter 11 Case. The Retention Order authorizes NPM to be compensated on an hourly basis and reimbursed for actual and necessary out-of-pocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct.

10. On October 11, 2022, Genever (BVI) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

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

12. On 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 [ECF No. 970].

13. On November 17, 2022, the Court granted Genever (BVI)'s application to retain NPM as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., October 11, 2022 [ECF No. 1107].

14. On October 12, 2020, Genever (US) filed a voluntary petition for relief under chapter 11 of the Bankruptcy 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").

15. On November 3, 2022, the SDNY Bankruptcy Court entered an order [ECF 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.

16. On November 21, 2022, the Court entered an order granting joint administration of the Genever (US) chapter 11 case with the jointly administered cases of the Individual Debtor and

the Genever (BVI) Debtor's chapter 11 case [ECF No. 1141] (the Individual Debtor, Genever (BVI), and Genever (US) may hereinafter be collectively referred to as the "Debtors").

17. On November 30, 2022, the Court granted Genever (US)'s application to retain NPM 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 [ECF No. 1177]. IV. Prior Applications and Monthly Fee Statements

18. NPM sought the reimbursement of expenses incurred in its representation of the Trustee as local and conflicts counsel by application dated April 18, 2023, [ECF No. 1674] (the "Reimbursement Application"), which application was granted by order of this Court dated May 5, 2023, [ECF No. 1769].

19. By application dated June 1, 2023, NPM sought the allowance of fees for the period from the Petition Date through February 28, 2023 (the "First Interim Application") [ECF No. 1851]. The First Interim Application was granted by order of this Court dated June 29, 2023, allowing the Applicant interim compensation in the amount of \$551,718.50 [ECF No.1966].

20. By application dated August 4, 2023, NPM sought the allowance of fees and reimbursement of expenses for the period from March 1, 2023 through June 30, 2023 (the "Second Interim Application") [ECF No. 2053]. The Second Interim Application was granted by order of this Court dated September 12, 2023, allowing the Applicant interim compensation in the amount of \$357,587.50 and reimbursement of expenses in the amount of \$10,402.59 [ECF No. 2192]. Pursuant to the Court's order granting the Second Interim Application, \$71,517.50 was held back from payment pending further order of the Court, half of which was later released ("Second Fee App Holdback").

21. By application dated October 18, 2023, NPM sought the allowance of fees and reimbursement of expenses for the period from July 1, 2023 through August 31, 2023 (the "Third Interim Application") [ECF No. 2260]. The Third Interim Application was granted by order of this Court dated November 30, 2023, allowing the Applicant interim compensation in the amount of \$280,180.00 and reimbursement of expenses in the amount of \$1,849.10 [ECF No. 2410].

22. By application dated February 19, 2024, NPM sought the allowance of fees and reimbursement of expenses for the period from September 1, 2023 through December 31, 2023 (the "Fourth Interim Application") [ECF No. 2936]. The Fourth Interim Application was granted by order of this Court dated March 20, 2024, allowing the Applicant interim compensation in the amount of \$1,038,670.00 and reimbursement of expenses in the amount of \$34,929.96 [ECF No. 3021], as amended by Amended Order dated March 27, 2024 [ECF No. 3050]. Pursuant to the Court's order granting the Fourth Interim Application, \$203,734.00 was held back from payment pending further order of the Court, half of which was later released ("Fourth Fee App Holdback").

23. By application dated June 25, 2024, NPM sought the allowance of fees and reimbursement of expenses for the period from January 1, 2024 through April 30, 2024 (the "Fifth Interim Application") [ECF No. 3287]. The Fifth Interim Application was granted by order of this Court dated July 26, 2024, allowing the Applicant interim compensation in the amount of \$1,351,385.50 and reimbursement of expenses in the amount of \$17,663.61 [ECF No. 3359]. Pursuant to the Court's order granting the Fifth Interim Application, \$135,138.55[2] was held back

2 Additionally, pursuant to the order granting the Fifth Interim Application, NPM was paid fifty (50%) percent of the Second Fee App Holdback and Fourth Fee App Holdback. Moreover, NPM reserved the right to seek compensation for fees in the amount of \$5,341.50 associated with services related to Despins, Chapter 11 Trustee v. Hing Chi Ngok, et al. (Adv. Proc. No. 24-05273) (the "Civil RICO Action") during the application period of the Fifth Interim Application.

from payment pending further order of the Court ("Fifth Fee App Holdback" and together with the Second Fee App Holdback and the Fourth Fee App Holdback, the "Prior Holdbacks").

24. On August 16, 2024, pursuant to the Interim Compensation Procedures Order, NPM filed its Monthly Fee Statement for Compensation and Reimbursement of Expenses for Period from May 1, 2024 Through June 30, 2024 [ECF NO. 3443] (the "May-June Monthly Fee Statement") attaching NPM's itemized fees for the months of May and June, 2024 and requesting payment of 80% of all fees for services rendered and 100% of all expenses incurred for such month (i.e., \$446,533.20 in fees and \$13,791.20 in expenses). No objections were filed to NPM's May-June Monthly Fee Statement such that the amounts requested for payment were paid on October 3, 2024.

25. On September 17, 2024, pursuant to the Interim Compensation Procedures Order, NPM filed its Monthly Fee Statement for Compensation and Reimbursement of Expenses for Period from July 1, 2024 Through July 31, 2024 [ECF No. 3539] (the "July Monthly Fee Statement" and, together with the May-June Monthly Fee Statement, the "Application Period Monthly Fee Statements") attaching NPM's itemized fees for the month of July 2024 and requesting payment of 80% of all fees for services rendered and 100% of all expenses incurred for such month (i.e., \$241,491.20 in fees and \$2,474.24 in expenses). No objections were filed to NPM's July Monthly Fee Statement and as a result the amounts requested for payment were paid on October 10, 2024.

26. NPM did not file a Monthly Fee Statement for the month of August 2024 and has included its itemized fees and expenses for August 2024 in this Application. SIXTH INTERIM FEE APPLICATION OF PAUL HASTINGS LLP AND INCORPORATION BY REFERENCE

27. Paul Hastings LLP ("Paul Hastings") is lead counsel to the Trustee, Genever (BVI), and Genever (US) in these Chapter 11 Cases. As discussed herein, throughout the course of these Chapter 11 Cases, NPM has worked cooperatively with Paul Hastings as Connecticut counsel and conflicts counsel to the Trustee and as co-counsel with respect to Genever (BVI) and Genever (US) (collectively, the "Genever Debtors").

28. On October 15, 2024, Paul Hastings filed its *Sixth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from April 1, 2024 through August 31, 2024* [ECF No. 3700] (the "PH Application"). The PH Application contains extensive discussion of the history of these Chapter 11 Cases and the nature of legal services performed for the Trustee and the Genever Debtors. To avoid repetition, NPM incorporates the PH Application herein by reference.

29. In the interest of efficiency and reducing administrative expense, throughout the Trustee's investigation and asset-recovery efforts, and the administration of these Chapter 11 Cases, the Trustee and Paul Hastings have requested and NPM has performed legal services with respect to substantive, administrative, and procedural issues (e.g., preparing, reviewing and revising pleadings, presenting and arguing discovery motions, serving subpoenas and court orders, requesting adjournments and approving stipulations, preparing monthly operating reports, interacting with clerks' offices and chambers and coordinating logistics for hearings, and attending to other case administration functions as they arise). NPM's counsel have also advised with respect to this district's local rules and practices and has assisted the Trustee at court hearings throughout these Chapter 11 Cases. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 11 of 446

30. This support has both ensured that the Trustee and the Genever Debtors understood and complied with local rules and practices—and has also resulted in substantial administrative cost savings in these Chapter 11 Cases.

31. The Applicant is applying for compensation pursuant to Sections 330 and 331 of the Bankruptcy Code for legal services performed for the Trustee, Genever (BVI), and Genever (US) during the Application Period.

32. For the Application Period, the Applicant seeks allowance of fees in the amount of \$1,254,303.00, as compensation for services rendered in connection with such services. This amount reflects (a) a \$20,000.00 voluntary reduction, which NPM has assessed as a courtesy to the Trustee, the Genever Debtors, and the bankruptcy estates; and (b) that NPM is not presently requesting allowance of its fees (in the amount of \$6,467.00) incurred with respect to the Civil RICO Action, provided, however, NPM reserves the right to request allowance and payment of such fees in the future.

33. The Applicant devoted 2,860.6 hours to this case during the Application Period, equating to an overall blended rate of \$445.47.

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

35. Annexed hereto and made a part hereof as Exhibit E is a detailed billing report, broken down by project category, upon which this application is based that contains each individual professional's time for the Debtors' bankruptcy proceedings, itemizing the dates upon Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 12 of 446

which services were rendered, including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the dollar value of such services. A summary of the foregoing is attached hereto as Exhibit B.

36. Annexed hereto and made a part hereof as Exhibit F is a detailed report of costs and expenses incurred by the Applicant during the Application Period. A summary of the foregoing is attached hereto as Exhibit C.

37. During the Application Period, the following summarizes the services provided by the Applicant on behalf of the Trustee:

a. advising the Trustee as to his investigation into the property of the Individual Debtor's estate (the "Estate"), including his pursuit of actions to collect and recover property for the benefit of the Estate;

b. commencing, conducting, and/or continuing litigation necessary and appropriate to assert rights held by the Estate, protect assets of the Estate, or otherwise further the goal of completing the Chapter 11 Case;

c. preparing and reviewing, on behalf of the Trustee, necessary and appropriate applications, motions, proposed orders, other pleadings, notices, schedules, and other documents, and reviewing financial and other reports filed and to be filed in the Chapter 11 Case;

d. advising the Trustee concerning, and preparing responses to, applications, motions, other pleadings, notices, and other papers that may be filed by other parties in the Chapter 11 Case; Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 13 of 446

e. reviewing the nature and validity of any liens asserted against the property in these Chapter 11 Cases and advising the Trustee concerning the enforceability of any liens;

f. assisting the Trustee in the investigation, recovery, marketing, and disposition of estate assets; and

38. During the Application Period, the following summarizes the services performed by the Applicant as counsel to the Genever Debtors:

a. preparing, reviewing, and revising the monthly operating reports for the Genever Debtors; and

b. corresponding with the Genever (BVI) Director, the U.S. Trustee's office, the Trustee, and co-counsel regarding the monthly operating reports for the Genever Debtors. CATEGORIZATION OF SERVICES AND CATEGORY SUMMARIES

39. As is its practice as counsel to trustees or debtors in chapter 11 cases, NPM has organized its time by category in respect to the nature of the services it provided to the Trustee and the Genever Debtors. All services provided to the Genever Debtors fell within the Case Administration category, and thus this category is divided between services provided to the Trustee and to the respective Genever Debtors. More specifically, the services provided under each category and NPM's summaries of same are as follows: A. Case Administration: Fees: \$4,481.50 Total Hours: 11.5

40. During the Application Period, NPM prepared and filed operating reports on behalf of the Genever Debtors, including those for March, April, May, June, and July 2024. In connection with these services, NPM communicated with the Genever (BVI) Director, the Trustee, co-counsel Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 14 of 446

at Paul Hastings and counsel for the Sherry Netherland regarding issues related to the operating reports, the security deposit maintained by the Sherry Netherland, and bank statements for the Genever (US) account. B. Asset Disposition: Fees: \$9,058.50 Total Hours: 18.3

40. NPM performed services to assist the Trustee with liquidating assets for the benefit of the Estate. These services included drafting and filing the Trustee's motion requesting authority to liquidate shares of Victory Capital Holdings Inc. (the "VCTR Shares") and responding to Lamp Capital's objection to this motion. As a result, on June 12, 2024, the Court granted the Trustee's Motion for Order Approving Liquidation of VCTR Shares. [ECF No. 3244]. C. Asset Analysis and Recovery: Fees: \$397,621.50Total Hours: 877.6

41. NPM assisted the Trustee in investigating, preserving, and recovering assets for the benefit of the Estate.

42. The investigation by NPM has primarily taken the form of Bankruptcy Rule 2004 examinations and subpoenas. During the Application Period, NPM pursued discovery from numerous subpoena targets, including banks, affiliated entities, and individuals, to ascertain the extent of Individual Debtor's assets and recover the same for the benefit of the Estate.

43. Throughout the Application Period, NPM worked with Paul Hastings to prepare supplemental motions under Bankruptcy Rule 2004 seeking discovery from various individuals and entities. Specifically, on May 16, 2024, NPM counsel drafted and filed the Trustee's Fifteenth Omnibus Bankruptcy Rule 2004 Motion, which the Court granted on May 28, 2024. [ECF Nos. 3193, 3223]. Additionally, NPM counsel drafted and filed the Sixteenth Omnibus Bankruptcy Rule 2004 Motion, which the Court granted on August 26, 2024. [ECF Nos. 3398, 3454]. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 15 of 446

44. Additionally, NPM worked in conjunction with Paul Hastings to prepare, issue, and enforce compliance with numerous subpoenas with respect to the above-mentioned motions and prior Bankruptcy Rule 2004 Motions. Moreover, NPM worked with the Trustee and opposing counsel regarding the Court's order compelling DBS Bank to comply with the Trustee's subpoena and NPM negotiated with several other financial institutions to obtain compliance with the Trustee's subpoenas notwithstanding jurisdictional and other objections. By meeting and conferring with counsel for many subpoena targets, NPM was often able to narrow or resolve objections to the Trustee's Bankruptcy Rule 2004 subpoenas and thus to obtain information useful to the Trustee's investigation and valuable to the Estate without litigation.

45. In addition to obtaining production from subpoena targets, NPM assisted in reviewing and analyzing documents and information produced by subpoena targets. Further, NPM worked closely with professionals from Kroll, LLC ("Kroll"), the Trustee's forensic investigator, in order to ascertain further entities and subjects requiring investigation and to identify and close any "gaps" within the universe of documents and information obtained by the Trustee to date. NPM also worked cooperatively with Kroll to facilitate analysis of the documents and information obtained in the Trustee's Bankruptcy Rule 2004 investigations—which analysis has been leveraged in preparing and prosecuting the Trustee's litigation claims.

46. As a result of, among other things, discovery through Rule 2004 Motions, the Trustee uncovered critical information, including email domains maintained by Microsoft and Google accounts connected to the Individual Debtor's alter-egos. NPM requested Microsoft to voluntarily preserve the email domains to prevent the Individual Debtor's co-conspirators from destroying potentially valuable information. Microsoft declined this request. In order to preserve information that may be valuable to the Trustee's investigation (and thus the Individual Debtor's Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 16 of 446

estate) contained within the Microsoft domains and Google accounts, NPM prepared and filed a Motion to Seal Motion for Order to Preserve Evidence. [ECF No. 3307], which the Court granted over Microsoft's objection [ECF No. 3353]. In connection with this motion and a related reply memorandum, NPM researched and analyzed legal issues under the Stored Communications Act. As a result of the foregoing, NPM successfully obtained relief directing Microsoft and Google to preserve digital property of the Estate, specifically cloud-based email servers under domains utilized by the Individual Debtor's alter egos, Lamp Capital and Golden Spring.

47. In May of 2024, the NPM assisted the Trustee in investigating a limited partnership owned by the Estate through Lamp Capital LLC in Reverence Capital Partners Opportunities Fund I (Cayman) L.P. (the "Reverence Fund"), which was the defendant in one of the Trustee's Avoidance Actions. By communicating with the Reverence Fund's management, as well as Merrill Lynch, NPM attorneys assisted the Trustee in securing the estate's interest in the fund, and in obtaining a consensual liquidation of certain securities distributable to the Estate (i.e., the VCTR Shares) as well as cash distributions. These efforts resulted in the Estate realizing \$2,747,783.59 from the liquidation of distributable securities [ECF No. 3372] and more than \$2.5 million in cash distributions during the Application Period. Thus the Estate has realized well more than \$5 million in value from the Estate's interest in the Reverence Fund during the Application Period.

48. Additionally, NPM attorneys represented the Trustee in an appeal filed by Mei Guo and her counsel to the U.S. Court of Appeals for the Second Circuit of a contempt order and sanctions order issued in the main chapter 11 case by the Bankruptcy Court in early 2023. [Docket No. 24-1271 ECF No. 30.1]. Mei Guo and her attorneys had previously appealed the same orders to the District Court. The District Court affirmed the Bankruptcy Court's orders by decision dated April 5, 2024. NPM attorneys performed all tasks concomitant with Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 17 of 446

representing the Trustee as the appellee, including preparation and filing of appearances, attention to motion practice and legal research regarding the same, coordination with appellants' counsel regarding the appendix (and related review of appendices employed below in the prior appeal to the District Court), preparation and filing of notices required by the local rules, and conferring with the Trustee regarding all of the foregoing, including outlining applicable rules and timelines for briefing and adjudication of the appeal. NPM attorneys also analyzed certain legal issues implicated by this appeal and advised the Trustee with respect to same.

49. Also during this Application Period, NPM attorneys took the lead in preparing the Trustee's appellate brief in the pending appeal of adv. pro. 23-5008, Brief of the Appellee, Luc. A. Despins, Chapter 11 Trustee [Docket 3:24-cv-00724-KAD No. ECF 18], which was completed and filed approximately two weeks after the conclusion of the Application Period. Services by NPM attorneys during the Application Period include: (a) reviewing the underlying record of summary judgment including documents submitted in reply to the defendant's opposition to the Trustee's motion; (b) reviewing and analyzing the appellant's brief and researching and analyzing arguments and caselaw therein; and (c) outlining and crafting the argument sections in the Trustee's brief.

50. Moreover, during the Application Period NPM assisted in monitoring events during the Individual Debtor's criminal trial to ensure confidentiality of sensitive information relating to the bankruptcy case and otherwise assisted with the Trustee's investigation of the Individual Debtor's assets and financial affairs. [3]

3 On July 18, 2024, the Individual Debtor was convicted in federal court of nine felony counts, i.e., racketeering conspiracy, conspiracy to commit wire fraud and bank fraud, money laundering conspiracy, conspiracy to commit securities fraud, wire fraud in connection with the Farm Loan Program, securities fraud in connection with the Farm Loan program, wire fraud in connection with G|CLUBS, securities fraud in connection with G|CLUBS, and Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 18 of 446 D. Avoidance Action Analysis: Fees \$291,693.00 Total Hours: 707.2

51. Prior to the Application Period, NPM worked with the Trustee, Kroll, and Paul Hastings to commence over 270 actions (the "Avoidance Actions") on or shortly before the twoyear anniversary of the Petition Date and to extend the time limitations set forth in the Bankruptcy Code to commence additional avoidance actions.

52. As a result of the Court's Order [ECF No. 3186] extending the applicable statutes of limitations set forth in the Bankruptcy Code, NPM investigated and filed approximately thirty additional Avoidance Actions during the Application Period and continued to actively litigate previously filed actions. NPM undertook key tasks to advance these actions, including:

a. Extensive review and analysis of the Individual Debtor's financial transactions undertaken via his alter egos. In consultation with Kroll and Paul Hastings, NPM also investigated the business affairs of potential defendants in Avoidance Actions and the connections between such entities and individuals and the Individual Debtor (including his alter egos). NPM used this investigation and analysis to advise the Trustee and pursue additional Avoidance Actions.

b. During the Application Period, NPM attorneys drafted and filed approximately thirty new Avoidance Action complaints arising from alleged fraudulent transfers and/or unauthorized postpetition transfers under the Bankruptcy Code and applicable state laws. This involved further analysis of avoidance claims to prepare complaints based upon the following: the applicable alter egos, the unauthorized prepetition and postpetition transfer amounts, as well as claims (prepetition, postpetition,

wire fraud in connection with the Himalaya Exchange. See United States v. Ho Wan Kwok, case no. 1:23-cr-00118-AT [ECF No. 395] (July 18, 2024 S.D.N.Y.). Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 19 of 446

or both) in the various Avoidance Actions. NPM prepared both sealed and unsealed versions of said complaints and appropriately handled confidential information contained therein.

c. During the Application Period, NPM attorneys served the Trustee's new Avoidance Action complaints within the United States and, as to both new and existing Avoidance Action complaints, worked with Paul Hastings and other counsel for the Trustee in foreign countries to accomplish service of the Trustee's new and existing Avoidance Action complaints throughout the world. In connection with this task, NPM attorneys assisted with researching information necessary to serve the corresponding summons and complaint, analyzing whether service was properly effectuated, and the drafting of many dozens of affidavits of service.

d. After the Avoidance Actions were filed and served, NPM filed applicable notices, appearances and certificates of service. NPM also analyzed potential defenses to these actions. Notably, NPM collaborated with Paul Hastings to prepare and file more than a dozen objections to defendants' motions to dismiss in pending Avoidance Actions. NPM took the lead in drafting many of these oppositions and worked collaboratively with Paul Hastings throughout the process.

e. During the Application Period, as part of NPM's efforts to recover assets for the Trustee, NPM attorneys continued to attend numerous court hearings related to the applicable procedures and prosecution of the Avoidance Actions. Prosecution of the Avoidance Actions also included preparing and filing amended complaints, responding to motions to dismiss, and addressing confidentiality issues. Moreover, NPM attorneys Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 20 of 446

analyzed the Avoidance Actions to address non-responsive defendants and prepared numerous requests for entry of defaults, which were subsequently granted.

f. In consultation with the Trustee, NPM attorneys negotiated, prepared and entered into Tolling Agreements with parties which enabled the Trustee and the tolling parties additional time to review and discuss the resolution of claims without the costs associated with ongoing litigation. The Tolling Agreements were approved by the Court after submission under seal by NPM. As a result of the Tolling Agreements, NPM successfully negotiated, prepared and filed settlement agreements and stipulated judgments with multiple tolling parties.

g. Significantly, NPM attorneys collaborated with Paul Hastings attorneys in implementing a large-scale mediation program, which the Trustee and opposing counsel have utilized to explore resolution of the Trustee's avoidance claims against more than 40 defendants. NPM attorneys also prepared and prosecuted a motion to approve prelitigation mediation procedures to allow the Trustee to explore settlement with potential defendants before putting claims in suit, which motion the Court granted [ECF Nos. 3396, 3465]. NPM attorneys have represented the Trustee in these mediation programs to reach or make progress towards settlements with numerous Avoidance Action defendants.

h. Finally, NPM attorneys assisted Paul Hastings attorneys in seeking and obtaining a further extension of time for the Trustee to commence Avoidance Actions. [ECF No. 3329].

53. Overall, NPM played a crucial role in managing and executing the various tasks involved in commencing and prosecuting Avoidance Actions during the Application Period in order to recover assets for the benefit of the Estate. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 21 of 446

54. During the Application Period, NPM separately organized and categorized its time incurred with respect to specific Avoidance Actions by project codes specific to such Avoidance Actions. NPM separately summarizes these services in the summary attached as Exhibit D and the nature of the services is specifically described in NPM's fee statements attached to this Application. NPM has continued to categorize within the general Avoidance Action Analysis category its services performed in connection with (a) all or multiple Avoidance Actions (e.g., services performed in connection with generally applicable mediation procedures), (b) investigating and preparing to commence actions to prosecute avoidance claims, and (c) negotiating with potential avoidance defendants prior to the Trustee commencing suit. E. Fee/Employment Applications: Fees: \$42,394.00 Total Hours: 108.2

55. NPM attorneys worked with the Trustee and Paul Hastings in the preparation and prosecution of several retention and fee applications during the Application Period. As an initial matter, NPM prepared and prosecuted its Fifth Interim Fee Application. NPM also prepared and filed the May-June and July 2024 Monthly Fee Statements.

56. During the Application Period, NPM assisted the Trustee with preparing and filing fee applications for the Trustee' s retained tax firm Eisner Advisory Group LLC ("Eisner"). NPM worked directly with Eisner to prepare, finalize and file its fee application.

57. In the previous application period, NPM drafted and submitted the fee application for certain of the Trustee's legal counsel outside the United States, i.e., Paul Wright and Harney Westwood & Riegel, LP. During this Application Period, NPM attended hearings to address inquiries from the Committee and the United States Trustee on the subject of Paul Wright's fee application. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 22 of 446

58. NPM assisted in the preparation of and filed the application to retain Compass, Inc. as the Connecticut real estate agent for the Trustee to market and sell the real property located at 373 Taconic Road, Greenwich, Connecticut. And NPM assisted the Trustee in engaging counsel in New Jersey to attend to matters involving the Mahwah Mansion (as defined herein), for which counsel a retention application was filed after the Application Period. F. Adversary Proceedings (and Related Appeals):

59. During the Application Period, NPM attorneys worked with Paul Hastings attorneys in the prosecution of both adversary and appellate proceedings. More specifically, NPM counsel performed the following services: (i) Greenwich Land Adv. Proc. 23-5005: Fees: \$43,299.00 Total Hours: 91.1

60. This adversary proceeding (the "Greenwich Land A.P.") concerns the Trustee's claims against Greenwich Land LLC ("Greenwich Land") and Hing Chi Ngok (the Individual Debtor's alleged wife) that the company defendant and its assets are property of the Estate.

61. During the Application Period, NPM assisted in analyzing a favorable decision on summary judgment from the Court, finding that Greenwich Land's assets are property of the Estate based upon alter ego and Ms. Ngok's membership interest in Greenwich Land is property of the Estate based upon beneficial ownership. (the "Summary Judgment") [Greenwich Land A.P. ECF No. 134][4] . Greenwich Land's primary asset was an approximately 12,000 square foot home located at 373 Taconic Road, Greenwich, Connecticut (the "Greenwich Property").

62. Subsequent to entry of Summary Judgment, NPM attorneys assisted the Trustee in addressing a motion for stay pending appeal filed by the Defendants and ultimately assisted the

4 On July 10, 2024, a notice of appeal to the Summary Judgment was filed followed by a motion for stay pending appeal [Greenwich Land A.P. ECF 138 and 139]. On August 16, 2024, a Consent Order Resolving Motion for Stay Pending Appeal and Enforcing Summary Judgment was entered by the Court. [Greenwich Land A.P. ECF 166]. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 23 of 446

Trustee in negotiating, drafting, and implementing the Consent Order Resolving Motion for Stay Pending Appeal and Enforcing Summary Judgment [Greenwich Land A.P. ECF No. 166], pursuant to which the Trustee gained possession of the Greenwich Property.

63. NPM worked with the Trustee and Paul Hastings to preserve the Greenwich Property for the benefit of the estate. NPM drafted and recorded instruments of title to vest title to the Greenwich Property in the Trustee for the benefit of the Estate. NPM assisted the Trustee in preparing the Greenwich Property for marketing and sale, including review of title issues affecting the Greenwich Property, researching conveyance tax issues, reviewing and addressing insurance coverage, coordinating property walkthroughs with security personnel to ensure it was properly secured, and addressing security, maintenance, and repair needs as they arose. (ii) HK USA/Interpleader Adv. Proc. 22-5003, 23-5012: Fees: \$990.00 Total Hours: 2.00

64. This adversary proceeding (the "HK USA/ Interpleader Adversary Proceeding") relates to the possession of the Individual's Debtor's escrow funds in connection with the Individual Debtor's yacht "Lady May". During the Application Period, U.S. District Court affirmed this Court's summary judgment decision in favor of the Trustee. NPM attorneys performed all tasks concomitant with representing the Trustee in the defendant's appeal of the summary judgment, including preparation and researching the defendant's appellant brief. (iii) Sherry Netherland Adv. Proc. 23-5002: Fees \$1,499.00 Total Hours: 3.6

65. This adversary proceeding (the "Sherry Netherland Possession Adversary Proceeding") relates to possession of the Individual Debtor's penthouse apartment at the Sherry Netherland Hotel. During the Application Period, NPM worked with counsel at Paul Hastings to adjourn a pretrial conference, consult with opposing counsel, and preserve the Trustee's rights. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 24 of 446 (iv) Mei Guo Adv. Proc 23-5008: Fees: \$ 3,883.50 Total Hours: 9.0

66. This adversary proceeding (the "Mei Guo/Aircraft Adversary Proceeding") relates to the proceeds from the unauthorized postpetition sale of the Individual Debtor's Bombardier Global XRS private jet with serial number 9189 (the "Bombardier"), held in the name of Whitecroft Shore Limited ("Whitecroft"), a shell company nominally owned by the Individual Debtor's daughter. Prior to this Application Period, the Court granted the Trustee's summary judgment motion, ruling that the Trustee is the beneficial owner of Whitecroft and the sale proceeds (the "Aircraft Order"), which order was appealed by the defendant Mei Guo. Thus, through this adversary proceeding, the Trustee has recovered for the benefit of the Estate more than \$10 million of proceeds from the unauthorized postpetition sale of the Bombardier. Certain claims in this adversary proceeding (involving shell companies in the British Virgin Islands) have not yet been decided and, during the Application Period, NPM counsel researched those shell companies and issues related to the Trustee's remaining claims in preparing to seek further relief in this action. (v) HCHK Adv. Proc. 23-5013: Fees: \$8,439.50 Total Hours: 17.3

67. This adversary proceeding (the "HCHK Adversary Proceeding") concerns the "HCHK Entities," i.e., entities that the Trustee believes are alter egos of the Individual Debtor that are in possession of more than \$38 million in assets. Prior to the Application Period, the Court granted the Trustee's Motion for Default Judgment. During this Application Period, NPM worked with the Trustee to respond to the defendants'and proposed intervenors' notices of appeal and motions to stay enforcement of the judgment. The U.S. District Court has since denied the defendants' and the proposed intervenors' motions for stay pending appeal, following which the defendants and the proposed intervenors have abandoned their appeals. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 25 of 446 (vi) Mahwah Adv. Proc. 23-5017: Fees: \$22,670.00 Total Hours: 47.6

68. This adversary proceeding (the "Mahwah Adversary Proceeding") concerns a luxury residential estate (the "Mahwah Mansion") in Mahwah, New Jersey, and the Trustee's claims that, among other things, this asset is property of the Estate. Prior to this Application Period, NPM attorneys prepared and filed an adversary proceeding against Taurus Fund, Scott Barnett, and Taurus Management LLC, seeking a determination that the Individual Debtor's Mahwah Mansion is property of the Estate.

69. During the Application Period, NPM attorneys assisted the Trustee in, among other things, addressing with the Court the defendants' termination of funding for security services that guard the Mahwah Mansion in violation of the Court's preliminary injunction order. Upon the Trustee learning that the defendants had ceased all funding for and maintenance of the Mahwah Mansion, NPM took the lead in drafting a motion and amended motion to allow the Trustee to use Estate funds to preserve the value of the Mahwah Mansion pending disposition of the Mahwah Adversary Proceeding [Adv. Proc. 23-5017 ECF Nos. 113, 124], which the Court granted. (vii) Golden Spring Adv. Proc. 23-5018: Fees: \$1,342.00 Total Hours: 3.6

70. This adversary proceeding (the "Golden Spring Adversary Proceeding") concerns the Trustee's claims that Golden Spring (New York) Ltd. (the "Golden Spring") is the Individual Debtor's alter ego or is beneficially owned by the Individual Debtor. Prior to the Application Period, the Court granted the Trustee's default judgment against the defendants.

71. During the Application Period, NPM gathered and analyzed document production from Golden Spring's prior counsel, Cohn Birnbaum & Shea. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 26 of 446 (viii) Lamp Capital Adv. Proc. 23-05023: Fees: \$396.50 Total Hours: 0.9

72. In this adversary proceeding (the "Lamp Capital Adversary Proceeding"), the Trustee sought, among other things, declaratory relief to the effect that Lamp Capital LLC ("Lamp Capital"), Infinity Treasure Management Inc. ("Infinity"), Hudson Diamond NY LLC, and Leading Shine NY Ltd, and their property, are property of the Estate. Prior to the Application Period, the Court granted the Trustee's motion for default judgment against Lamp Capital and Infinity. On March 19, 2024, NPM prepared for and attended a hearing on certain defendants' (i.e., Leading Shine NY Ltd. Mei Guo, Hudson Diamon NY, LLC, and Hudson Diamond Holding LLC) motion to dismiss, which the court denied. [ECF No. 87]. (ix) Ace Decade Adv. Proc 23-5028 Fees: \$25,506.00 Total Hours: 52.6

73. In this adversary proceeding (the "Ace Decade Holding Limited Adversary Proceeding") the Trustee seeks to set aside the transfer of the ownership of Ace Decade Holdings Limited ("Ace Decade"), which the Court has found is beneficially owned by the Individual Debtor, by Yanping ("Yvette") Wang to Rui Hao.

74. During the Application Period, among other things, NPM attorneys prepared and filed a request for entry of default against Yvette Wang and after which default was entered against her. Subsequently, NPM counsel worked with Paul Hastings attorneys to draft and file a motion for default judgment against these defendants. Later, following service of defendant Rui Hao in Switzerland, NPM attorneys prepared and filed a request for entry of default against Mr. Hao and, thereafter, a motion for default judgment against him. In connection with the foregoing, NPM attorneys prepared for and attended several hearings. NPM attorneys also worked with Paul Hastings in responding to and ultimately defeating efforts by purported liquidators to delay the Trustee's relief in this action. As a result of these efforts, the Court has granted the Trustee default Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 27 of 446

judgments against Ace Decade, Ms. Wang, and Mr. Hao [Docket No. 23-05028 ECF Nos. 73, 82], ruling, among other things, that Ms. Wang's transfer of the interest in Ace Decade Holdings to Mr. Hao was in violation of the automatic stay under Section 362(a) of the Bankruptcy Code and therefore void. (x) Civil RICO Adv. Proc. 24-05273 Fees: \$6,467.00 Total Hours: 13.8

75. NPM is not requesting allowance of fees for services performed with respect to the Civil RICO Action at this time but will do so in the future and will discuss its services in this action at that time. (xi) ACA Capital Group Adv. Proc. 24-05249 Fees: \$22,400.00 Total Hours: 52.0

76. In this adversary proceeding (the "Omnibus Alter Ego Adversary Proceeding") the Trustee seeks, among other things, declaratory relief to the effect that ACA Capital Group Ltd., Alfa Global Ventures Limited, Alfonso Global Ventures Limited, Anton Development Limited, Bravo Luck Limited, China Golden Spring Group (Hong Kong) Ltd., Eastern Profit Corporation Limited, Freedom Media Ventures Limited, G Club International Limited, G Club Operations LLC, G Fashion (CA), G Fashion Hold Co A Limited, G Fashion Hold Co B Limited, G Fashion International Limited, GFashion Media Group Inc., G Music LLC, GF IP, LLC, GF Italy, LLC, GFNY, Inc., Hamilton Capital Holding Limited, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Haoran Ge, Himalaya Currency Clearing Pty Ltd., Himalaya International Clearing Limited, Himalaya International Financial Group Limited, Himalaya International Payments Limited, Himalaya International Reserves Limited, Jovial Century International Limited, K Legacy Ltd., Karin Maistrello, Leading Shine Limited, Major Lead International Limited, Qiang Guo, Rule of Law Foundation III Inc., Rule of Law Society IV, Inc., Saraca Media Group, Inc., Seven Mission Group LLC, William Je, and Wise Creation Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 28 of 446

International Limited and their property, are alter egos of the Individual Debtor and/or that the Individual Debtor beneficially owned these entities such that they and their assets are property of the Estate.

77. During the Application Period, NPM drafted and filed requests for entry of default against Qiang Guo and K Legacy, Ltd. Since then, the Clerk granted said requests for default.

78. On August 27, 2024, NPM attorneys prepared and prosecuted a motion for default judgment against defendant K Legacy Ltd. and Qiang Guo collectively, the ("Default Defendants") as to liability on the Thirty-Seventh Claim in the Omnibus Alter Ego Adversary Proceeding Complaint. Subsequently, on September 12, 2024, the Court granted the Trustee's default judgment which ordered the ownership interests and assets in K Legacy Ltd., including Apartment 6 and G3 at 5 Princess Gate, London, United Kingdom SW7 1QJ, are property of the Estate. (xii) Bouillor Holdings Limited, et al. Adv. Proc. 24-05311 Fees: \$1,683.00 Total Hours: 3.4

79. In this adversary proceeding (the "Bouillor Holdings Adversary Proceeding") the Trustee seeks to recover the Individual Debtor's luxurious high-rise apartment at Number 23-03 in the "One Limassol" building in Limassol, Cyprus (the "Cyprus Apartment"), held in the name of Bouillor Holdings Limited ("Bouillor"), a Cyprus entity nominally owned by Qiang Guo, the Individual Debtor's son.

80. During the Application, Period NPM attorneys assisted Paul Hastings with the preparation, filing and service of the complaint in the Bouillor Holdings Adversary Proceeding. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 29 of 446 (ix) Specific Avoidance Actions: Fees: \$394,952.50 Total Hours: 850.[8]5

81. As noted above, since March 2024, NPM has separately categorized its fees incurred in pending Avoidance Actions. The foregoing fees and hours represent the aggregate of time devoted to the prosecution of specific Avoidance Actions during the Application Period.

82. Among other things, NPM attorneys (a) negotiated with counsel for defendants in Avoidance Actions regarding extensions of time to respond to the Trustee's complaints, (b) engaged in settlement discussions, (c) assisted in organizing and attending mediation sessions, (d) investigated and researched claims and defenses in pending Avoidance Actions, (e) prepared amended complaints in more than twenty-five Avoidance Actions, and (f) drafted and filed objections to defendants' motions to dismiss Avoidance Actions.

83. The Trustee's services specific to pending Avoidance Actions are discussed in greater detail in the summary attached hereto as Exhibit D.

84. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee and Genever Debtors in connection with the chapter 11 proceedings herein.

5 This time is specifically categorized by Avoidance Action as set forth in NPM's May, June and July 2024 Fee Statements under the following project codes: L613, L614, L616, L618, L619, L620, L622, L623, L625, L626, L627,L628, L629, L631, L633, L635,L636, L637, L639, L640, L641, L642, L643, L644, L645,L647, L648, L650, L649, L651, L652, L653, L654, L655, L656, L657, L658, L662, L663, L664, L666, L667, L668, L669, L670, L671, L672, L673, L674, L675, L676, L677, L678, L679, L681, L682, L683, L684, L685, L686, L688, L689, L691 L692,L693, L694, L695,L696, L697, L698, L699, L701, L702, L703, L704, L708, L709,L710, L711, L712, L714, L715, L716, L717, L718, L719 L721, L722, L723, L724, L725, L726,L727, L728, L729, L731, L734, L736, L735, L737, L739, L740, L741, L742, L743, L744,L745, L750, L754,L755, L756 L758, L761, L763, L767, L770, L772, L771, L773, L774, L775, L776, L777, L779, L780, L786, L790, L791, L792, L793 ,L794, L795, L797, L798, L799, L802,L803, L805, L804, L808, L809, L810, L811, L814, L815, L816, L817,L818, L820, L822, L823, L824, L828, L830, L831, L833, L834, L835, L838, L839, L842, L847, L851, L854, L855, L856 ,L857, L859, L869, L872, L875, L86, L877, L878, L879,L881, L882, L886, L890, :896, L897, L903, L904 L905, L906, L910, L913, L916, L917, L917, L919, L920, L922, L924 L920, L921, L926, , L932, L933, L934, L941, L943, and L944. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 30 of 446

85. NPM respectfully submits that its services have benefited the Trustee and the Genever Debtors with the expertise and skill required in the handling of bankruptcy matters. The legal services for which such compensation is requested were performed for and on behalf of the Trustee and the Genever Debtors. Such services have been necessary to protect and enforce the rights and interests of the Trustee and the Genever Debtors in connection with the Chapter 11 Cases. The reasonable value of services rendered by NPM in these proceedings is based upon NPM's usual hourly rates for matters of this nature.

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

87. 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).[6]

88. 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

6 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 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 31 of 446

necessary and beneficial, whether the services were performed in a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communications Systems, Inc., 395 B.R. 512, 516 (D. Conn. 2008).

89. 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. 488 F.2d 714 (5th Cir. 1974) (abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87 [1989]), [7] while also bearing in mind that a "reasonable, paying client wishes to spend the minimum necessary to litigate the case effectively." 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). 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.[8] See In re Nine Assocs., Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine Magazine, Inc., 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); Green v. City of New York, 403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); see generally 3 COLLIER ON BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing First Colonial and Johnson as the "leading

7 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.

8 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 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 32 of 446

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

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

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

92. NPM 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

Period?

Response: No. Question: If the fees sought in this application as compared to the fees

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 14.4 hours and associated fees of approximately \$3695.00 related to preparing, reviewing, and revising NPM's monthly fee statements and ensuring time entries are properly categorized by matter number and task code. NPM notes that, without obligation to do so, NPM wrote off certain time devoted to reviewing invoices in connection with its monthly fee statements. - 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: The Application contains approximately 3.9 hours and associated fees of \$780 to review time records related to any tolling party information. - 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 and contemplated by the terms of its engagement and the Court's orders approving same, NPM 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, 2024, NPM adjusted its hourly rates consistent with the Retention Order [ECF No. 668] and the Notice of Change in Hourly Rates of Neubert, Pepe & Monteith, P.C. [ECF No. 2454].

93. There exist Prior Holdbacks of \$272,764.30 (i.e., \$35,758.75 under the Second Fee App Holdback, \$101,867 under the Fourth Fee App Holdback, and \$135,138.55 under the Fifth Fee App Holdback). NPM consents that the Prior Holdbacks remain in effect.

94. Upon consultation with the United State Trustee, NPM has consented to a 10% holdback with respect to the fees it requests for allowance during this Application Period, i.e., \$127,430.30.

95. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or NPM has for any reason not sought compensation or reimbursement with respect to such services, NPM reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these Chapter 11 Cases. Also, NPM 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.

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

[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.] Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 35 of 446

WHEREFORE, NPM respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of \$1,254,303.00, (ii) allowing compensation for expenses incurred in the amount of \$23,054.71, (iii) authorizing and directing payment of 90% of the fees and all of the expenses allowed and awarded for the Application Period, (iv) allowing such compensation and payment for professional services rendered without prejudice to NPM's right to seek further compensation and/or payment from the Debtors' estates for the full value of services performed and expenses incurred, and/or to seek release of any amounts that remain subject to a holdback, and (v) granting NPM such other and further relief as is just.

Dated: October 15, 2024 New Haven, Connecticut

> By: /s/ Patrick R. Linsey Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 821-2000 dskalka@npmlaw.com plinsey@npmlaw.com

> > Counsel to Luc A. Despins, Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

**[PROPOSED] ORDER GRANTING SIXTH INTERIM APPLICATION OF NEUBERT, PEPE & MONTEITH, P.C., AS LOCAL AND CONFLICTS COUNSEL TO THE CHAPTER 11 TRUSTEE AND AS COUNSEL TO DEBTORS GENEVER HOLDINGS CORPORATION AND GENEVER HOLDINGS LLC FOR ALLOWANCE OF FEES AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM MAY 1, 2024 THROUGH AUGUST 31, 2024**

Upon consideration of the Application [ECF No. \_\_\_] (the "Application") of Neubert, Pepe & Monteith, P.C. ("NPM") as counsel to the Trustee[2] and the Genever Debtors for sixth interim allowance of compensation and reimbursement of expenses from May 1, 2024 through August 31, 2024; and sufficient notice having been given; and a hearing having been held on \_\_\_\_\_\_\_\_\_ and due consideration having been given to any responses thereto; and sufficient cause having been shown therefor, it is hereby:

1. ORDERED that, pursuant to 11 U.S.C. §§ 330 and 331, the Application is granted as set forth herein and compensation in the amount of \$1,254,303.00 (the "Awarded Fees") and

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

2 Capitalized terms not otherwise defined herein adopt the definitions set forth in the Application. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 38 of 446

reimbursement of expenses in the amount of \$23,054.71 (the "Awarded Expenses") is awarded to NPM, subject to final adjustment and disgorgement in the event all administrative expenses are not paid in full or as provided in the order approving the sale of the Lady May [ECF No. 1953]; and it is further

2. ORDERED that NPM's right to seek allowance in future fee applications of fees associated with services related to the Civil RICO Action shall be reserved; and it is further

3. ORDERED that the Debtors' estates are authorized to pay NPM (a) ninety (90%) of the Awarded Fees (i.e., \$1,146,872.70) and (b) 100% of the Awarded Expenses, and the remaining 10% of Awarded Fees shall be held back by the Debtors' estates pending further order of this Court; and it is further

4. ORDERED that the Prior Holdbacks (i.e., \$272,764.30) shall remain held back pending further order of the Court; and it is further

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

6. ORDERED that the Trustee and NPM are authorized and empowered to take all necessary actions to implement the relief granted in this Order; and it is further

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

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

(Summary of Compensation by Project Category)

Task Code and Project Category Hours Billed Fees Billed

B110 Case Administration 11.5 \$4,481.50 B120 Asset Analysis and Recovery 877.6 \$397,621.50

B160 Fee/Employment Applications 108.2 \$42,394.00 B180 Avoidance Action Analysis 707.2 \$291,693.00 B230 Financing/ Cash Collateral .2 \$99.00

L250 Other Written Motions and Submissions 2.5 \$1,248.50 L510 Appellate Motions and Submissions .8 \$384.00

L603 HK USA/Interpleader A.P. # # 22-5003, 23-5012 2.0 \$990.00

et al.

L953 Bouillor Holdings Limited et al, A.P. # 24-05311 3.4 \$1,683.00

Project Categories for Specific Avoidance Actions 850.8 \$394,952.50

E107 Delivery Services/Messengers \$6,510.67

E118 Litigation Support Vendors \$130.35

(Summary of Services of Avoidance Actions) Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 42 of 446

Code Name Hours Fees Summary of Services Rendered

24-05006 43.80 \$19,360.50 Draft memorandum to Attorney

mediation;

avoidance transfers;

and Nagamine;

mediation;

avoidance claims;

complaint;

production for defendant;

extend time to respond.

-24-05007 5.80 \$2,796.00 Prepare for and engage in settlement negotiations with Attorney Manfrey;

negotiations;

negotiations;

-24-05008 2.60 \$1,287.00 Communication with Attorney Farmer regarding appellee designations;

avoidance claims;

an Lamborghini;

defendant's claims.

24-05010 1.40 \$684.00 Communication with Attorney

extend time to respond; Draft and revise mediation letter;

mediation.

-24-05011 5.70 \$2,439.00 Draft and revise motion to request entry of default;

default. L620 Ogier -24-05012 .60 \$283.00 Communication with Attorney Sklarz

to respond;

of service to Attorney Linsey;

dismiss.

-24-05015 2.80 \$1,302.00 Communication with Attorney

mediation position; Draft and revise mediation letter;

Gottesman;

regarding settlement offer.

-24-05017 3.50 \$1,732.50 Communication with Attorney Bassett regarding avoidance claims; Prepare for and attend call with U.S. Attorney and counsel;

an investigation of a Bugatti.

Corp. -24-05018 3.60 \$1,782.00 Examine documents related to the motion to request entry of default;

entry of default.

05019 .50 \$242.50 Review and analyze defendant's answer to complaint;

concerning service.

05020 5.50 \$2,722.50 Communication with Lesa Slaughter regarding avoidance claims;

default;

services and asserted defenses;

entry of default.

Advisors, Inc. - 2.10 \$962.00 Draft and revise stipulation to extend time to respond;

Chorches regarding discovery. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 45 of 446

23-05023 .10 \$42.50 Prepare and analyze applicable

concerning service.

Media 8.30 \$3,862.50 Draft and revise stipulation to extend

to complaint;

documents;

transferees in the complaint;

avoidance action;

avoidance claims.

-24-05027 18.40 \$8,925.50 Draft motion for leave to

amended complaint;

avoidance complaint;

entry of default;

complaint;

complaint;

amended complaint.

24-05028 .50 \$212.50 Draft and file certificate of service.

05028 .30 \$127.50 Draft and file certificate of service.

Fund -24-05030 7.10 \$3,326.50 Advise Trustee of settlement negotiations and discovery;

automatic stay; Examine discovery documents;

complaint;

Inc. -24-05031 1.50 \$742.50 avoidance complaint. Draft and revise mediation letter;

issues;

procedures.

-24-05032 .50 \$247.50 Prepare for and engage in

Attorney Gilbert;

regarding status of settlement.

24-05033 11.90 \$4,889.50 Prepare for and engage

counsel;

regarding the status of settlement;

proposals;

agreement; Draft and revise stipulated judgment.

Inc. -24-05034 32.80 \$13,628.00 Prepare for and attend settlement

Rosenblatt;

regarding the status of settlement;

Dime Bank;

with the defendant;

extend time to respond;

defendant.

Media, Inc. -24-05035 2.10 \$1,050.00 Draft and revise mediation letter;

regarding the mediation letter.

-24-05036 .30 \$148.50 Communication with Attorney

discovery.

24-05038 .10 \$42.50 Prepare and analyze applicable

concerning service.

24-05039 .50 \$209.00 Draft and revise motion to request entry of default.

24-05040 .50 \$247.50 Communication with Attorney Major regarding the status of discovery.

05041 2.20 \$1,068.00 Draft memorandum to Attorney

discovery;

avoidance claims;

the avoidance complaint; Draft and file certificate of service.

L651 Restoration 7.20 \$3,353.00 Communication with Attorney

Hardware, Inc. Thompson regarding mediation;

to extend time to respond;

concerning the Rule 26(f) report;

entry of default;

of avoidance transfers. L652 Loro Piana 1.60 \$767.50 Prepare and analyze applicable

concerning service;

motion to request entry of default. L653 Teris-Phoenix, 2.50 \$1,286.50 Revise mediation letter;

-24-05044 Communication with Attorney Skalka

the mediation letter;

regarding the status of mediation. L654 The Quinlan 2.20 \$1,010.00 Draft and revise an amended Law Firm,LLC - avoidance complaint.

L655 Janco SRL-24- .10 \$42.50 Prepare and analyze applicable

concerning service.

L656 Phillips Nizer 3.80 \$1,829.00 Negotiation and draft stipulation LLP extend time to respond;

mediation letter;

and stipulations;

Plan and prepare for mediation;

regarding mediation counter offers;

concerning service.

-24-05048 .90 \$495.00 Draft and revise mediation letter;

mediation letter. L658 VFT Solutions 4.00 \$1,912.50 Negotiation and draft stipulation Inc. -24-05049 extend time to respond;

extend time to respond;

regarding the mediation letter;

Draft and revise mediation letter;

avoidance claims;

Judge Tancredi. L662 H Shaw 5.90 \$2,570.50 Advise Trustee of settlement Enterprises LLC negotiations;

agreement;

regarding settlement agreement;

Sutton;

Attorney Corwin.

L663 Style Eyes Inc. 1.70 \$800.00 Negotiation and draft stipulation

d/b/a Ginger extend time to respond;

discovery. L664 270 W. 39th St. 1.30 \$691.50 Revise mediation letter;

-24-05055 Negotiation with defendant's counsel

mediation;

procedures.

L666 Amazon.com, 5.90 \$2,543.50 Communication with Attorney Inc. Peterson regarding avoidance claims and confidentiality issues;

time to respond;

banks related to avoidance claims;

regarding avoidance claims;

avoidance complaint.

L667 Anthem Health 1.30 \$612.50 Draft and revise mediation letter;

to extend time to respond. L668 Federal Express 3.00 \$1,375.50 Advise Trustee of status of pleadings;

mediation;

Draft and revise mediation letter;

regrading the status of mediation.

extend time to respond;

and Feeny;

banks related to avoidance claims;

from mediation;

production;

Angelich regarding motion to dismiss;

Relativity;

motion to dismiss.

LLC-24-05061 4.10 \$1,956.50 Draft and revise motion to request entry of default;

regarding settlement proposals; Draft and revise settlement proposal;

regarding settlement offers. L671 Appsflyer Inc. -24-05062 2.60 \$1,225.00 Prepare for and engage in settlement

counsel;

mediation; Draft and revise mediation letter.

-24-05063 5.10 \$2,541.50 Examine documents related to avoidance claims; Draft and revise mediation letter;

designations;

extend time to respond;

mediation letter;

claims.

LLC-24-05064 2.30 \$789.50 Prepare and analyze applicable

concerning service;

entry of default;

Jones.

& C. -24-05065 .10 \$42.50 Prepare and analyze applicable

concerning service.

-24-05066 2.50 \$1,188.00 Prepare and analyze applicable pleadings;

avoidance actions;

entry of default.

Enterprises Inc. -24-05067 12.00 \$5,733.50 Prepare and analyze applicable

concerning service;

complaint;

entry of default;

avoidance complaint.

-24-05068 2.70 \$1,336.50 Communication with Attorney

amended order;

regarding motion to dismiss.

-24-05069 14.50 \$6,719.50 Draft and revise mediation letter;

entry of default;

dismiss;

regarding request for entry of default;

concerning service;

defendant's motion to dismiss.

Cleaning, Inc. -24-05070 2.50 \$1,237.50 Prepare and analyze applicable pleadings;

avoidance claims;

concerning service. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 54 of 446

24-05072 .20 \$85.00 Communication with Attorney Linsey

entry of default.

24-05073 .40 \$170.00 Draft and revise motion to request entry of default.

-24-0574 2.70 \$1,375.00 Draft and revise mediation letter;

letter;

mediation.

05075 .10 \$42.50 Prepare and analyze applicable

concerning service.

Manhattan, Inc. -24-05076 2.70 \$1,336.50 Draft and revise mediation letter;

with Attorney Kaelin;

mediation;

Debtor's vehicle;

negotiations.

-24-05077 13.40 \$6,334.00 Communication with Attorney Skalka regarding Amex discovery issues;

concerning avoidance claims;

discovery;

on status of avoidance claims;

Draft and revise mediation letter.

05079 .10 \$42.50 Prepare and analyze applicable pleadings concerning service.

S.R.L -24-05080 .10 \$42.50 Prepare and analyze applicable

concerning service.

-24-05082 1.50 \$825.00 Draft and revise mediation letter;

mediation.

-24-05083 3.80 \$1,701.00 Communication with Attorneys

avoidance claims;

statement;

avoidance claims;

extend time to respond;

avoidance claims.

Inc. -24-05084 .80 \$372.50 Communication with Attorney

extend time to respond. L694 Vandenloom Inc. -24-05085 4.10 \$1,807.50 Draft and revise motion to request entry of default;

entry of default.

24-05086 .30 \$67.50 Draft memo with copies of motion to dismiss to Attorney Linsey.

SRL -24-05087 .10 \$67.50 Prepare and analyze applicable pleadings concerning service.

L697 Tokyoseiki Co. LTD. -24-05088 4.80 \$2,271.00 Draft and revise an amended avoidance complaint;

complaint.

05089 .10 \$42.50 Prepare and analyze applicable

concerning service.

Design Inc. -24-05090 3.00 \$1,485.00 Prepare and analyze applicable pleadings;

entry of default.

Corp. -24-05092 .20 \$95.00 Draft and revise mediation letter.

24-05093 2.70 \$1,143.00 Draft and revise motion to request entry of default;

default.

Calzature S.R.L.

24-05094 .10 \$42.50 Prepare and analyze applicable

concerning service.

05095 1.70 \$577.50 Communication with Attorney

for appointment of process server;

Attorney Bassett.

Association, Inc. -24-05099 .10 \$22.50 File stipulation to extend time to respond. L709 Grocyber, LLC 3.50 \$1,748.00 Communication with Attorneys

services;

procedures;

Draft and revise mediation letter;

related to avoidance claims.

24-05101 6.00 \$2,802.00 Draft and revise motion to request entry of default;

to default defendant;

extend time to respond;

default.

24-05102 .40 \$170.00 Prepare and analyze applicable pleadings concerning service.

24-05103 3.90 \$1,462.50 Prepare and analyze applicable

concerning service;

entry of default. L714 N87 Inc. -24-05105 2.90 \$1,435.50 Prepare and analyze applicable

concerning service;

entry of default;

avoidance claims.

-24-05106 .30 \$165.00 Communication with Attorney

settlement.

-24-05107 2.00 \$990.00 Prepare and analyze applicable pleadings concerning service;

entry of default.

LLC 15.50 \$7,566.50 Communication with Attorneys

of mediation;

and stipulations;

conference;

extend time to respond.

mediation letter.

Inc. 25.90 \$11,341.50 Draft memorandum to Attorney

mediation letter;

negotiations;

production;

the defendant's document production;

Barron and Bassett;

claims; Draft and revise mediation letter;

avoidance claims;

letter;

settlement. L719 Aaron Mitchell 5.90 \$2,839.50 Communication with Attorney Sklarz -24-05110 regarding a motion for extension of time;

dismiss to Attorney Bassett;

defendant's motion to dismiss. L721 Empire Blue 2.20 \$1,023.00 Negotiation and draft stipulation Cross Blue to extend time to respond;

-24-05112 Draft and revise mediation letter;

the caption of the avoidance action;

the avoidance action. L722 1322089 B,C, .30 \$127.50 Prepare and analyze applicable

concerning service;

L723 ModSquad Inc. 4.40 \$2,196.50 Prepare for and engage in settlement -24-05114 negotiations with Attorney Pesce;

claims and defenses; Draft and revise mediation letter. L724 Cloudflare, Inc. 3.70 \$1,947.50 Prepare for and engage in settlement -23-05115 negotiations with Attorney Streusand;

mediation;

status of settlement negotiations.

Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 60 of 446

-24-05116 .20 \$99.00 Communication with Attorney

avoidance action.

Inc. -24-05117 23.50 \$11,557.50 Communication with Attorney

mediation;

transactions involving the defendant;

Angelich regarding motion to dismiss;

defendant's motion to dismiss;

conferences;

mediation;

from mediation.

to complaint;

to complaint;

Ahumada.

24-05119 3.20 \$1,353.00 Draft and revise motion to request entry of default;

entry of default.

Circle, LLC 3.50 \$1,804.00 Draft and revise mediation letter;

-24-05120 Prepare for and engage in settlement

Kaelin;

regarding the mediation letter.

24-05122 .30 \$141.50 Prepare for and engage in settlement negotiations with Attorney Reding.

05125 .60 \$255.00 Prepare and analyze applicable

concerning service;

regarding service issues.

-24-05126 2.60 \$1,287.00 Draft and revise motion to request entry of default;

concerning service.

24-05127 .10 \$42.50 Prepare and analyze applicable

service.

Motorcars Inc. -24-05128 6.20 \$3,069.00 Examine documents related to location of the Debtor's Rolls Royce;

recovery;

negotiations with Attorney Seltzer.

Improvement, 6.50 \$3,131.50 Negotiate

to respond to complaint; Inc.

mediation;

to complaint;

Draft and revise mediation letter;

L740 Lawrence River 1.90 867.50 Draft and revise an amended

24-05131 avoidance complaint. L741 JM Bullion Inc. -24-05132 5.20 \$2,537.50 Draft a notice of dismissal of the avoidance action;

defendant's answer to the complaint;

avoidance action;

Attorney Bassett.

-24-05133 6.30 \$3,073.00 Communication with Attorney Ladd

mediation; Draft and revise the mediation letter;

avoidance action from mediation;

Associates P.A 24.90 \$11,883.00 Research and draft

defendant's motion to dismiss;

regarding the protective order;

to dismiss;

dismiss;

defendant's motion to dismiss.

motion to dismiss;

mediation;

mediation;

dismiss.

24-05136 2.50 \$1,216.50 Prepare and analyze applicable

concerning service;

negotiations with Attorney Serise;

service issues;

negotiations.

24-05141 2.80 \$1,300.00 Negotiation and draft stipulation for extension of time to respond;

counsel.

Motors, Inc. 2.30 \$1,107.50 Communication with Attorney Brown concerning the avoidance claims;

time to respond;

regarding the status of mediation.

L755 Fortnum 3.90 \$1,839.50 Draft and file certificate of service;

Security Limited Draft and revise an amended

24-05146 avoidance complaint;

certificate of service. L756 Jamestown .20 \$95.00 Draft and revise mediation letter.

Group, LLC Draft and revise motion to request -24-05149 entry of default;

regarding a certificate of service;

Draft and file certificate of service. L761 Troutman .70 \$340.50 Communication with Attorneys Pepper Hamilton Lawall and Shaiken regarding Sanders LLP confidentiality issues;

issues.;

defendant's mediation inquiries. L763 Kamel Debeche 24.90 \$12,442.50 Communication with Attorney Nealon -24-05154 regarding discovery;

Linsey regarding discovery;

production;

concerning discovery. L767 RV Retailers 8.30 \$4,070.50 Negotiate

-24-05158 complaint;

the status of mediation;

with Attorney England;

status of settlement negotiations;

pleadings concerning mediation.

24-05161 2.50 \$860.50 Prepare and analyze applicable

concerning service;

request for entry of default;

entry of default.

-24-05162 3.20 \$1,598.50 Draft and revise mediation letter;

regarding avoidance claims;

transactions.

05163 25.50 \$12,567.50 Communication with Attorney

mediation;

of pleadings;

dismiss;

defendant's transfers;

jurisdiction over foreign entities;

motion to dismiss.

avoidance claims.

24-05165 2.10 \$945.00 Draft and revise an amended avoidance complaint;

amended avoidance complaint.

05166 4.10 \$1,952.50 Draft and revise

complaint;

amended avoidance complaint;

pleadings.

24-05167 31.20 \$14,075.50 Communication with Attorneys

avoidance claims;

avoidance transfers from Kroll;

avoidance complaint;

designations;

amended avoidance complaint;

avoidance complaint;

-24-05168 28.90 \$13,715.50 Draft and revise stipulation to extend

to complaint;

avoidance transfers.

dismiss;

defendant's motion to dismiss;

defendant's motion to dismiss.

24-05170 .80 \$340.00 Examine documents concerning the defendant's bankruptcy;

24-05171 .50 \$177.50 Draft and revise motion to request entry of default.

05177 .90 \$447.50 Prepare for and analyze pleadings

orders;

discovery.

-24-05181 1.50 \$734.50 Communication with Kroll

the defendant's avoidance transfers;

pleadings;

negotiations with Attorney Proscia.

to complaint;

Hernandez;

meeting.

-24-05183 .50 \$220.50 Assist Attorneys Bassett and

action.

-24-05184 .90 \$399.00 Review and analyze applicable

and documents;

counsel.

05185 4.20 \$2,084.00 Draft memorandum to Sarah

respond;

the status of mediation;

Pierce.

05186 7.10 \$3,322.50 Advise Trustee of settlement discussions;

negotiations with Attorney Willard;

defendant's relation to the Debtor;

service;

extend time to respond.

-24-05188 3.90 \$1,745.50 Communication with Attorney Corbi regarding the status of mediation;

dismiss;

avoidance action;

Barron;

motion to dismiss.

05189 8.10 \$3,717.00 Communication with Attorney

extend time to respond; Draft and revise mediation letter;

avoidance claims;

business;

avoidance transfers;

regarding the status of mediation.

24-05190 1.20 \$660.00 Draft memorandum to Attorney

stipulations;

Draft and revise mediation letter.

Investment Ltd.

24-05193 5.50 \$2,434,00 Assist Attorney Barron with

transfers;

regarding the certificate of service;

avoidance complaint; Draft and file certificate of service.

-24-05194 1.00 \$495.00 Prepare for and engage in settlement negotiations with Attorney Placona.

24-05195 1.80 \$896.00 Communication with the Trustee and

claims;

Attorney Charmoy.

05196 1.20 \$590.00 Prepare for and engage in settlement negotiations with Attorney Moffett;

confidentiality issues;

negotiations.

24-05198 .70 \$140.00 Prepare for and analyze conflict searches of discovery targets;

documents.

motion to dismiss;

motion to dismiss;

dismiss. L809 Wedlake Bell 1.10 523.50 Prepare and analyze applicable

concerning service;

respond to complaint;

pleadings;

extend time to respond. L810 O.S.C. Orbit II 1.40 \$633.50 Draft and revise motion to request Service entry of default;

regarding request for default. L811 Clayman 1.40 \$620.00 Communication with Attorney Valauri Rosenberg regarding a stipulation to extend time Kirshner & to respond;

of pleadings. L813 G4S Security 1.60 \$522.00 Communication with Attorney Sklarz Systems (Hong regarding status of pleadings.

avoidance complaint. L814 Marini .20 \$99.00 Communication with Attorney Rogers

mediation.

L815 Hao Haidong – .40 \$198.00 Analyze complaint service issues.

L816 Bering Yachts, .70 \$367.00 Draft and revise mediation letter;

-24-05207 Communication with Attorney Kaelin regarding the status of pleadings.

John B.

05209 8.20 \$3,751.00 confidentiality agreement.

entry of default;

negotiations with Attorney Seitz;

web domains;

pleadings;

negotiations.

-24-5211 6.50 \$3,212.00 Communication with Attorney

pleadings; Draft and revise mediation letter;

negotiations with Attorney Charmoy;

to complaint.

24-05213 1.70 \$787.50 Communication with Attorney Bassett

settlement;

extend time to respond;

-24-05214 .10 \$42.50 Prepare for and engage in settlement

counsel. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 73 of 446

05215 2.70 \$1,290.00 Draft and revise

complaint;

avoidance claims.

05216 .10 \$42.50 Prepare and analyze applicable

concerning service.

-24-05219 26.70 \$12,447.50 Negotiation and draft stipulation to

to complaint;

regarding the status of pleadings;

motion to dismiss;

counsel;

defendant's motion to dismiss;

pleadings;

in the defendant's motion to dismiss.

-24-05221 .10 \$35.50 Communication with Attorney

conference.

Corp. -24-05222 3.00 \$1,492.50 Communication with Attorneys

status of pleadings;

Ahumada regarding the mediation; Draft and revise mediation letter.

Service Draft and revise motion to request

24-05224 entry of default. L834 Cirrus Design 1.70 \$815.50 Draft and revise mediation letter;

pleadings.

Ltd. 16.20 \$7,736.00 Research personal jurisdiction and minimum contacts caselaw;

avoidance complaint;

avoidance complaint.

-24-05229 1.70 \$777.50 Draft and revise mediation letter;

negotiations with the defendant; ;

negotiations. L839 Cayuse .40 \$198.00 Communication with Attorney Government Bennett regarding confidentiality Services, LLC issues.

L842 Brune Law PC 1.20 \$539.50 Prepare for and engage in settlement -24-05233 negotiations with the defendant;

pleadings. L847 Qiang Guo 9.10 \$3,832.00 Prepare and analyze applicable

concerning service;

the status of pleadings;

of service;

Draft and file certificate of service;

entry of default.

05242 1.10 \$515.00 Communication with

Eilenberg regarding avoidance claims; Attention to settlement negotiations.

05245 1.80 \$613.00 Assist Paul Hastings with preparing

for defendant.

-24-05246 .30 \$165.00 Draft memorandum to Sarah

stipulation to extend time to respond.

-24-05247 .90 \$431.50 Communication with counsel regarding discovery; Draft and revise scheduling order. L857 Curiosity Corp.

-24-05248 4.10 \$1,960.00 Draft and revise

complaint.

Corp. -24-05248 .20 \$99.00 Communication with Attorney

procedures.

24-05248 .10 \$42.50 Prepare and analyze applicable

complaint.

24-05250 3.60 \$1,660.00 Communication with Attorneys

status of pleadings;

Attorneys Smith and Trivigno;

motion to issue letter rogatory. L867 Gettr USA, Inc.

24-05252 5.20 \$2,476.00 Communication with Attorney Corbi regarding mediation procedures;

issues;

regarding the status of pleadings;

avoidance complaint.

24-05254 1.60 \$800.00 Communication with Attorneys

status of pleadings;

to complaint;

05257 .40 \$198.00 Communication with Attorney Powers

to complaint;

confidentiality issues.

24-05260 1.20 \$582.50 Communication with

extend time to respond.

24-05261 1.90 \$890.00 Draft and revise amended avoidance complaint.

05262 2.20 \$1,025.00 Draft and revise amended avoidance complaint.

-24-05263 1.40 693.00 Prepare and analyze applicable

concerning service;

support of avoidance claims.

24-04263 .50 247.50 Prepare and analyze applicable

of complaint;

action is subject to the motion to stay.

05263 .50 247.50 Prepare and analyze applicable

complaint;

Nutraceutical .30 \$148.50 Analyze avoidance complaint to

action is subject to the Court's stay.

24-05263 complaint.

05263 .40 \$142.00 Analyze the Bankruptcy Court's order affirming summary judgment.

24-05267 .20 \$110.00 Draft memorandum to Attorney

pleadings.

complaint;

complaint.

24-05269 1.20 \$594.00 Research issues relating to the

proceeding;

complaint.

Foundation Inc.

24-05269 2.00 \$990.00 Examine documents related to avoidance claims;

complaint.

24-05269 1.50 \$637.50 Draft and revise

complaint.

24-05270 .30 \$148.50 Communication with Attorneys

status of pleadings.

05271 2.70 \$1,336.50 Communication with Attorney Bassett

;

regarding the status of pleadings;

with Attorney Baranowski.

24-05271 .20 \$99.00 Prepare and analyze applicable

complaint.

05271 .20 \$42.40 Prepare and analyze applicable

complaint.

24-05271 .20 \$99.00 Analyze schedule of avoidance

to defendant.

05271 .30 \$89.50 Email to defendant's counsel

complaint;

to defendant.

24-05271 .40 \$80.00 Draft memorandum to Attorney

avoidance claims.

24-05271 .10 \$42.50 Prepare and analyze applicable

complaint.

-24-05272 .80 \$397.50 Communication with Attorney Baer

defendant;

against defendant .

-24-05272 .10 \$49.50 Communication with Attorney Baer regarding avoidance transfers.

24-05274 3.10 \$1,499.50 Draft and revise

complaint. Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 79 of 446

Cao -24-05001 1.50 \$742.50 Prepare for and attend hearing on

on the pleadings;

stipulation to extend time to respond. L933 Spears & Imes 10.70 \$3,767.50 Draft and revise tolling agreement;

to the Debtor;

regarding the status of pleadings;

counsel;

schedules in the avoidance complaint;

negotiations. L934 ACASS U.S.A. 4.50 \$1,673.00 Draft memorandum to Attorney

pleadings;

avoidance action;

to the avoidance procedures;

against defendant;

complaint;

Draft and file certificate of service.

24-05299 .10 \$42.50 Prepare and analyze applicable

Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 80 of 446

05301 .10 \$42.50 Prepare and analyze applicable

of complaint.

24-05302 .20 \$85.00 Prepare and analyze applicable

of complaint.

05275 1.90 \$730.50 Communication with Attorney

claims;

of complaint;

to complaint; Draft and file certificate of service.

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 1 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 82 of

550.00 0.30 165.00 Draft memorandum to attorneys Sadler

550.00 0.20 110.00 Bankruptcy Representation

550.00 0.40 220.00 Bankruptcy Representation

550.00 0.40 220.00 Bankruptcy Representation Review and revise operating report (.2);

550.00 0.40 220.00 Bankruptcy Representation Review revised operating report(.3); draft

550.00 0.10 55.00 Bankruptcy Representation

Despins, Ch 11 Trustee/Luc A.

550.00 0.30 165.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

550.00 0.20 110.00 Draft memorandum to attorney Barron

200.00 0.20 40.00 Bankruptcy Representation

Despins, Ch 11 Trustee/Luc A.

225.00 0.20 45.00 Filed FIFTH CONSENTED TO MOTION OF

Despins, Ch 11 Trustee/Luc A.

495.00 0.10 49.50 Arrange for hearing transcript

Despins, Ch 11 Trustee/Luc A.

200.00 0.20 40.00 Draft and file Attorney Kinsella appearance

Despins, Ch 11 Trustee/Luc A.

550.00 0.30 165.00 Draft memorandum to T. Jones regarding

revisions on Genever reports (.2); forward

220.00 0.50 110.00 Bankruptcy Representation

report and attachment(.4); Attend to filing Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 2 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 83 of

B110 A111 550.00 0.40 220.00 of the monthly operating report. (.1)

report (.1); draft memorandum to T. Jones

A B110 A101 220.00 0.40 88.00 Genever Holdings Corporation

operating report and the attachment. (.3)

B110 A111 550.00 0.70 385.00 Genever Holdings LLC

report and May operating report (.4); draft

revisions and status of reports(.2); draft

A B110 A101 220.00 0.20 44.00 Genever Holdings LLC

report for filing with the bankruptcy court.

A B110 A101 220.00 0.30 66.00 Bankruptcy Representation

attachment to same.

P B110 A101 200.00 0.70 140.00 Genever Holdings LLC

Despins, Ch 11 Trustee/Luc A.

B110 A111 550.00 0.20 110.00 Ho Wan Kwok, Debtor

status of operating report and filing issues

P B110 A101 200.00 0.20 40.00 Bankruptcy Representation

Despins, Ch 11 Trustee/Luc A.

B110 A111 550.00 0.40 220.00 Draft memorandum toattorneys Sadler

P B110 A101 200.00 0.10 20.00 E-mail Annecca Smith transcript from July

Despins, Ch 11 Trustee/Luc A.

A B110 A101 220.00 0.50 110.00 Ho Wan Kwok, Debtor

B110 A111 550.00 0.40 220.00 Review operating report (.3))Draft

A B110 A101 220.00 0.70 154.00 Bankruptcy Representation

case) (.2); Prepare draft June 2024 monthly Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 3 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 84 of

B110 A111 550.00 0.50 275.00 operating report (.3); Prepare draft

Review and revise operating report(.3);

B110 A101 220.00 0.30 66.00 Finalize and revise the June 2024 monthly

operating report for filing.

B110 A103 200.00 0.30 60.00 File VCTR report on sale and print for

Despins, Ch 11 Trustee/Luc A.

B110 A103 200.00 0.60 120.00 Serve VCTR sale report and trustees fourth

Despins, Ch 11 Trustee/Luc A.

B110 A111 550.00 0.20 110.00 Draft memorandum to attorney Sadler

B110 A107 495.00 0.20 99.00 Correspond and confer with D. Barron

Despins, Ch 11 Trustee/Luc A.

B110 A111 550.00 0.40 220.00 Review operating report; Draft

Total for Phase ID B110 Billable 11.50 4,481.50 Case Administration

Phase ID B120 Asset Analysis and Recovery

B120 A101 200.00 0.40 80.00 Attention to supplemental production

same to sharefile and draft memo to S.

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 1.00 425.00 Research contact information for

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 correspond w Kroll regarding specific

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.90 382.50 finish revisions to N3Q memorandum and

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.30 127.50 Research attorney for Bank of China, serve

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 1.50 637.50 Draft templates for tracking of ADP

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 4 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 85 of

Client Date Tkpr P Task Code Rate to Bill Amount Ref # Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.30 127.50 Confer w P. Linsey regarding organization 21494

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 1.90 807.50 Revise schedule of ADP records related to 21495

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.30 127.50 Review correspondence regarding 2004 21496

Despins, Ch 11 Trustee/Luc A.

P B120 A103 500.00 0.70 350.00 Prepare stipulation extending time to 22113 answer. Despins, Ch 11 Trustee/Luc A.

P B120 A107 500.00 0.50 250.00 Telephone J. Baumgartner regarding draft, 22114

stipulation filed. Despins, Ch 11 Trustee/Luc A.

P B120 A108 495.00 4.00 1,980.00 Correspond with Merrill Lynch and C. 22383

confidentiality designations issue (0.5),

discovery matters (0.2), work on Microsoft letter and correspond and confer with K. Mitchell regarding same (0.5), correspond with trustee regarding Microsoft letter re: property of the estate (0.1), confer with S. Fox (Merrill Lynch) regarding stock issue

for call with FDIC (0.2), confer with A.

Despins, Ch 11 Trustee/Luc A.

A B120 A107 495.00 1.60 792.00 Correspond and confer with A. Bongartz ARCH

same (0.2), correspond with clerk and T.

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 5 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 86 of

Phase ID B120 Asset Analysis and Recovery

B120 A104 355.00 0.10 35.50 Review schedules of alter ego entities from

Despins, Ch 11 Trustee/Luc A.

B120 A104 355.00 0.20 71.00 Review letter from ADP and corresponding

Despins, Ch 11 Trustee/Luc A.

B120 A105 355.00 0.50 177.50 Confer with Attorneys K. Mitchell, S.

Smeriglio regarding ADP production (.3); confer with K. Mitchell regarding same (.2) Despins, Ch 11 Trustee/Luc A.

B120 A101 425.00 0.80 340.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.30 127.50 Confer with L. Astone and S. Smeriglio

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review correspondence with Bank of

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review response from Supreme Fintech

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.30 127.50 Research Microsoft's registered agent for

Despins, Ch 11 Trustee/Luc A.

B120 A105 355.00 0.30 106.50 Confer with Attorneys L. Astone and K.

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Follow up with ADP regarding GS

Despins, Ch 11 Trustee/Luc A.

B120 A104 355.00 2.70 958.50 Review/analyze ADP production for

for Kwok entities and employees (2.5);

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Correspond w L. Astone regarding ADP

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 correspond w E. Cohen regarding service

Despins, Ch 11 Trustee/Luc A.

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 6 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 87 of

Phase ID B120 Asset Analysis and Recovery

B120 A104 425.00 0.30 127.50 Review notes from and documents Kroll

regarding DBS ties to other Kwok entities Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 1.50 637.50 Review ADP schedules related to Kwok

Despins, Ch 11 Trustee/Luc A.

B120 A103 355.00 0.60 213.00 Ho Wan Kwok, Debtor Prepare initial draft of motion to suspend

Despins, Ch 11 Trustee/Luc A.

B120 A104 495.00 1.90 940.50 Ho Wan Kwok, Debtor

production (0.5), correspond with E. Sutton

Despins, Ch 11 Trustee/Luc A.

B120 A104 355.00 2.00 710.00 Ho Wan Kwok, Debtor

(.5) and Gettr (.8) for purposes of updating

Despins, Ch 11 Trustee/Luc A.

B120 A103 355.00 2.70 958.50 Continue to draft and revise motion to

Despins, Ch 11 Trustee/Luc A.

B120 A102 355.00 2.20 781.00 Continue to research pleading standard

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 1.30 552.50 Review and revise ADP payroll schedules

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Review supplemental production from

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 1.30 552.50 Revise ADP schedule of employees and

Despins, Ch 11 Trustee/Luc A.

B120 A104 355.00 5.00 1,775.00 Review ADP production for Golden Spring,

Lamp Capital, and several other draft LLCs

Spring (2.5), Input ADP data for the Lost

Despins, Ch 11 Trustee/Luc A.

B120 A104 480.00 0.40 192.00 Review/analyze notice of appeal in

3:23-cv-00375 (ECF No. 43) (0.2); correspond with Attorney Linsey regarding

Despins, Ch 11 Trustee/Luc A.

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 7 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 88 of

Phase ID B120 Asset Analysis and Recovery

B120 A105 495.00 5.10 2,524.50 Ho Wan Kwok, Debtor

compliance progress (0.4), correspond and

criminal court docket filings and coverage

confidential bank records (3.3), correspond with N. Bassett and J. Kosciewicz regarding

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.80 340.00 Ho Wan Kwok, Debtor

to Debtor entities, employees and payroll Despins, Ch 11 Trustee/Luc A.

B120 A104 355.00 2.70 958.50 Call with Attorney N. Kinsella regarding

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 3.80 1,615.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A107 495.00 5.50 2,722.50 Correspond with N. Bassett regarding

motion to redesignate highly confidential bank statements (0.2), draft/revise motion to approve stipulated order with Aviation

correspond with K. Mitchell regarding ATC

revise motion (0.4), correspond with N.

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 1.40 595.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 4.00 1,700.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.40 170.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A104 355.00 5.50 1,952.50 Ho Wan Kwok, Debtor Research second circuit cases that survived

Date: 10/15/2024 Doc 3702 Filed 10/15/24

NEUBERT, PEPE & MONTEITH, P.C. Entered 10/15/24 22:22:27

Phase ID B120 Asset Analysis and Recovery a motion to dismiss in a section 550(a)(1) claim (2.5) Communicate with Attorney D. Carnelli regarding section 550(a)(1) claims

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.60 255.00 Research Relativity for Amazing Sky

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Follow up with ADP regarding GS Security

Despins, Ch 11 Trustee/Luc A.

B120 A103 355.00 0.20 71.00 Ho Wan Kwok, Debtor Initial draft of motion for extension of time

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.50 212.50 Review employees that were employed by

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with ADP and P Linsey

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.40 170.00 Review supplemental production from

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.90 495.00 Attend conference call with client and

attorney Linsey regarding discovery issues

Despins, Ch 11 Trustee/Luc A.

B120 A104 480.00 0.20 96.00 Review/analyze Notice of Appeal to 2nd

bankruptcy (re: specifically from sanctions order that was appealed in 3:23-cv-00375). Despins, Ch 11 Trustee/Luc A.

B120 A108 495.00 3.30 1,633.50 Correspond with C. McGushin regarding

further analysis required (0.4), confer with A. Lomas and K. Mitchell regarding further information needed from ADP (0.3), confer

Despins, Ch 11 Trustee/Luc A.

B120 A106 495.00 2.20 1,089.00 Correspond with trustee regarding

Reverence interest (0.1), correspond with L.

Fried and K. Mitchell regarding confidentiality designations motion (0.2),

Phase ID B120 Asset Analysis and Recovery correspond with K. Mitchell regarding further ADP analysis needed (0.3), review

(0.3), review and analyze Y. Wang criminal

correspond with S. Ingram (ATC) regarding

Despins, Ch 11 Trustee/Luc A.

B120 A106 495.00 2.20 1,089.00 Ho Wan Kwok, Debtor

Reverence interest (0.1), correspond with L.

confidentiality designations motion (0.2),

further ADP analysis needed (0.3), review

(0.3), review and analyze Y. Wang criminal

correspond with S. Ingram (ATC) regarding

Despins, Ch 11 Trustee/Luc A.

B120 A105 495.00 4.10 2,029.50 Correspond with D. Skalka regarding

confer with D. Skalka regarding mediation

correspond with D. Barron, N. Bassett and trustee regarding bucketing project (0.3),

presentation (0.7), correspond with D.

and confer with K. Ahumada regarding list

bucketing project (0.6), correspond with D.

correspond with D. Skalka and K. Mitchell regarding complaint against tolling party and further tolling (0.3), correspond with J.

(0.2), correspond with N. Bassett regarding

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.70 297.50 Con't revision of Master Employee ADP

Despins, Ch 11 Trustee/Luc A.

B120 A105 355.00 0.30 106.50 Ho Wan Kwok, Debtor

regarding service project (.1), Correspond

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 10 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 91 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

A102 355.00 0.80 284.00 Research whether service was effectuated

proceedings (.6), Phone call with Attorney

Despins, Ch 11 Trustee/Luc A.

A103 425.00 1.90 807.50 Ho Wan Kwok, Debtor

A105 425.00 0.20 85.00 Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

A103 425.00 0.40 170.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

A109 355.00 1.50 532.50 Ho Wan Kwok, Debtor

Skalka, Kinsella, Graham & Flynn to discuss

Despins, Ch 11 Trustee/Luc A.

A111 550.00 1.50 825.00 Ho Wan Kwok, Debtor

Linsey, Kinsella, Flynn, Smeriglio, Graham and Mitchell regarding status of avoidance

Despins, Ch 11 Trustee/Luc A.

A111 550.00 1.70 935.00 Ho Wan Kwok, Debtor Draft list of twenty non-stayed potentially

mediation eligible cases(.5); review dockets

A105 500.00 0.70 350.00 Despins, Ch 11 Trustee/Luc A.

the mediation letter process. Despins, Ch 11 Trustee/Luc A.

A101 500.00 1.40 700.00 Ho Wan Kwok, Debtor

adversary proceedings. Despins, Ch 11 Trustee/Luc A.

A107 500.00 0.20 100.00 Ho Wan Kwok, Debtor

regarding exchange of information. Despins, Ch 11 Trustee/Luc A.

A108 495.00 1.70 841.50 Ho Wan Kwok, Debtor

with N. Bassett regarding Baker Hostetler

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

B120 A108 495.00 4.40 2,178.00 response and correspond with A. Layden

outstanding discovery (0.3), confer with L.

Despins, Ch 11 Trustee/Luc A.

preparing avoidance actions for mediation

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 1.10 467.50 Continued analysis of ADP payroll records,

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 0.20 40.00 File transcript request for May 6 hearing

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 2.80 1,190.00 Analyze total data from ADP, consolidate

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.50 212.50 Revise Schedule of Employee payments

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review correspondence regarding

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.40 220.00 Review and update case tracker with latest

Despins, Ch 11 Trustee/Luc A.

B120 A101 500.00 0.70 350.00 Prepare and revise list of qualifying

adversary proceedings. Despins, Ch 11 Trustee/Luc A.

B120 A103 500.00 1.10 550.00 Draft/revise memo to Attorney Linsey

regarding mediation eligibility status of all assigned adversary proceedings. Despins, Ch 11 Trustee/Luc A.

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 12 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 93 of

Phase ID B120 Asset Analysis and Recovery

A111 550.00 0.40 220.00 Draft memorandum with summary of

regarding cases not yet mediation eligible

Despins, Ch 11 Trustee/Luc A.

A111 550.00 0.30 165.00 Ho Wan Kwok, Debtor

and Linsey regarding tolling extension and

Despins, Ch 11 Trustee/Luc A.

A108 495.00 2.30 1,138.50 Ho Wan Kwok, Debtor

consult (0.2), confer with A. Bongartz and

Reverence interest (0.4), correspond with

liquidation (0.2), correspond with S. Fox

account issues (0.1), confer with C. Fornos (G Club) and K. Mitchell regarding motion

Government and debtor filings in criminal case discussing fraud schemes (0.4), confer

Despins, Ch 11 Trustee/Luc A.

A105 495.00 2.50 1,237.50 Correspond with K. Mitchell regarding

registrations of vehicles (0.3), correspond

with B. Gilbert (NAV Consulting) regarding

Club designations (0.2), review and analyze

protective order (0.4), correspond with R. Barry regarding same (0.2), revise motion

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.30 127.50 Review producing parties with no

Despins, Ch 11 Trustee/Luc A.

A103 425.00 0.40 170.00 Revise Chase motion to compel,

Despins, Ch 11 Trustee/Luc A.

A103 425.00 0.70 297.50 Review and revise individual employee

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.10 42.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A. Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 13 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 94 of

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

P B120 A103 425.00 0.50 212.50 Ho Wan Kwok, Debtor Further revisions to Employee schedule to

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.40 220.00 Ho Wan Kwok, Debtor

extension of tolling agreement with tolling

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.50 275.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.50 275.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.90 495.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A101 495.00 3.50 1,732.50 Prepare for Kroll update call (0.3), attend

Kroll update call (0.8), correspond with M.

Yvette Wang issues (0.4), correspond with

correspondence from Mercantile Int'l Bank

order (0.3), correspond with J. Kosciewicz regarding same (0.2), correspond with D.

automatic stay (0.4), correspond with N.

Despins, Ch 11 Trustee/Luc A.

P B120 A108 495.00 3.00 1,485.00 Ho Wan Kwok, Debtor Correspond with S. Fox (Merrill) regarding

Reverence distribution (0.1), confer with S. Fox regarding same (0.2), correspond with

and proposed next steps (0.3), correspond

distribution and motion (0.2), confer with

distribution and motion (0.4), review and analyze H. Claiborn correspondence re: stock issue (0.2), correspond with R. Barry

Phase ID B120 Asset Analysis and Recovery with N. Bassett regarding same and draft

protective order (0.2), correspond with N. Bassett regarding Aviation Trust Co.

(0.3), correspond with N. Bassett regarding revisions to Aviation Trust Co. motion (0.2) Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.60 120.00 Confer with Attorney Flynn regarding

Qiang Guo (.1); begin drafting certificate of service (.3); Telephone call with Attorney Linsey regarding questions and concerns; draft e-mail to Attorney Linsey and Flynn

Despins, Ch 11 Trustee/Luc A.

P B120 A102 425.00 0.30 127.50 Research general counsel for Oriental bank

Despins, Ch 11 Trustee/Luc A.

P B120 A102 425.00 0.40 170.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 1.40 595.00 Review storage unit document

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.30 127.50 Review correspondence from ADP

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.60 255.00 Review supplemental production from

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.30 127.50 Revise 2004 exam subpoena notes to

reflect recent correspondence with targets Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Confer with FDIC regarding amended

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.10 42.50 Rec'v and review proposed language from

FDIC related to P.O. Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.10 42.50 Correspond w ULX regarding ADP

Despins, Ch 11 Trustee/Luc A.

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 15 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 96 of

Phase ID B120 Asset Analysis and Recovery

B120 A104 425.00 0.20 85.00 Review response from American Express

Despins, Ch 11 Trustee/Luc A.

B120 A108 495.00 3.40 1,683.00 Correspond with R. Barry regarding P.O.

confer with R. Barry regarding P.O.

(0.1), finalize motion to approve transfer of title of Ducati (0.4), correspond with K. Ahumada regarding filing and service (0.1),

Ducati motion (0.1), correspond with N.

Despins, Ch 11 Trustee/Luc A.

B120 A108 495.00 5.20 2,574.00 Correspond with S. Fox (Merrill) regarding

with trustee regarding Gertz bk filing and

ensure litigation hold on Gertz (0.2), work

Despins, Ch 11 Trustee/Luc A.

B120 A106 495.00 0.80 396.00 Lengthy correspondence with trustee and

Despins, Ch 11 Trustee/Luc A.

B120 A107 495.00 3.50 1,732.50 Correspond with N. Bassett regarding

status letter for Cheng v. Guo action (0.2),

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Rec'v correspondence from ADP

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 1.60 680.00 Research specified targets provided by

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 16 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 97 of

P Task Code Rate to Bill Amount Ref # Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 correspond w D. Skalka and P Linsey

regarding 2004 financial institution targets Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review correspondence with Kroll

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.90 382.50 Review Krasner computer records on

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond w Oriental Bank contact,

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.30 127.50 Revise 2004 motion subpoena tracker to

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Confer with P. Linsey regarding 2004 exam

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.70 385.00 Telephone attorney Linsey regarding

financial institution conflict reviews(.3) :

regarding searches and conflict reviews(.4) Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.40 220.00 Draft memo to courtroom deputy

extension and reasons for filing and court

Despins, Ch 11 Trustee/Luc A.

B120 A107 495.00 5.60 2,772.00 Correspond with A. Bongartz regarding

with trustee and N. Bassett regarding NPM weekly update (0.2), confer with D. Skalka

analysis (0.2), attention to Zoom hearing

trustee regarding same (0.3), revise motion to amend protective order to include P.O.

investigation and further analysis needed

Reverence questions (0.2), work on motion to approve VCTR liquidation per N. Bassett

(Merrill) regarding VCTR liquidation (0.2),

liquidation motion (0.2), correspond with

Phase ID B120 Asset Analysis and Recovery PHC1 and D. Barron regarding 15th Rule

motion (0.3), review and analyze associate RFP form (0.2), attention to J. Kosciewicz

Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.60 120.00 Attention to e-mail from Attorney Skalka

targets (.2); respond to same to Attorney

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.70 297.50 Revise 15th omnibus Rule 2004 motion to

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.70 297.50 Draft Exhibit B to 15th omnibus motion

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.50 212.50 Revise RFP for 15th 2004 exam individual

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.30 127.50 Confer w Chase regarding supplemental

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.60 255.00 Analyze supplemental Chase production

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.30 127.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.20 85.00 Review correspondence from Supreme

Fintech regarding meet and confer, confer

Despins, Ch 11 Trustee/Luc A.

P B120 A104 355.00 0.90 319.50 Review time entries in preparation to draft

fee app (.7); Phone call with Attorney N. Kinsella regarding fee application (.4) Draft Initial draft of Eisner fee application (.5) Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.40 220.00 Telephone attorney Moran regarding

change in designation on documents (.3);

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.50 275.00 Ho Wan Kwok, Debtor

status of mediation order and applicability

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.40 220.00 Ho Wan Kwok, Debtor

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 18 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 99 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

B120 A105 500.00 0.40 200.00 Communicate with team regarding status

and memoranda summarizing cases. Despins, Ch 11 Trustee/Luc A.

B120 A101 500.00 0.50 250.00 Ho Wan Kwok, Debtor

counsel for all assigned cases to maximize

adversary proceedings. Despins, Ch 11 Trustee/Luc A.

B120 A104 495.00 4.20 2,079.00 Ho Wan Kwok, Debtor

investigation (0.4), correspond with trustee

transfers (0.2), review and analyze A.

(0.4), confer with D. Skalka regarding same

further revisions to 15th Rule 2004 motion and review and analyze additional targets

accountant (0.3), confer with A.

VCTR liquidation issues (0.8), correspond with A. Calascibetta regarding tax analysis

Despins, Ch 11 Trustee/Luc A.

B120 A108 495.00 2.50 1,237.50 Correspond with C. McGushin regarding

VCTR liquidation (0.1), review and analyze

motion (0.3), correspond with K. Mitchell

(0.2), further revise 15th Rule 2004 motion (0.7), correspond with D. Barron and N. Bassett regarding same (0.2), confer with

(0.3), draft certificate of service for Ducati

Despins, Ch 11 Trustee/Luc A.

B120 A104 495.00 1.60 792.00 Work on appellee designation and analyze

filings in adversary proceeding in light of same (0.8), correspond and confer with W.

Phase ID B120 Asset Analysis and Recovery

B120 A104 425.00 0.20 85.00 regarding same (0.2), finalize appellee

Despins, Ch 11 Trustee/Luc A.

Rec'v and review correspondence from Citi

B120 A103 425.00 0.30 127.50 Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.60 255.00 Draft RFPs for newly added targets to 15th

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Correspond w K. Ahumada and P. Linsey

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.60 255.00 Research addresses for additional 2004

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.50 212.50 Further revisions of 15th supp motion and

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 1.20 510.00 Review documents from GSNY computers

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.30 127.50 Further revisions to 15th supplemental

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.00 Confer w A. Ahumada regarding updates

Despins, Ch 11 Trustee/Luc A.

B120 A103 355.00 1.80 639.00 Continue to draft interim fee application

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 1.70 340.00 Confer with Attorney Mitchell regarding

15th supplemental 2004 motion (.1); draft

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 0.10 20.00 Confer with K. Coleman regarding conflict

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.30 127.50 Review and revise 15th supp omnibus

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 20 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 101 of

Phase ID B120 Asset Analysis and Recovery

B120 A105 425.00 0.20 85.00 Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

B120 A105 200.00 0.10 20.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A110 200.00 1.00 200.00 Conduct conflict checks for 2004 exam

Despins, Ch 11 Trustee/Luc A.

B120 A108 495.00 0.50 247.50 Correspond with S. Fox regarding VCTR

with K. Mitchell regarding 15th Rule 2004

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.90 495.00 Review and revise amended tolling

revised stipulation(.2); draft memorandum

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 0.20 40.00 Draft and file request for transcript from

Despins, Ch 11 Trustee/Luc A.

B120 A101 220.00 4.30 946.00 Confer with Kelly Ahumada regarding

mailing of Fifteenth omnibus motion(.3); Prepare mailing and certification of same

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 2.40 480.00 File 15th supplemental omnibus discovery

motion (.4); confer with S. Pierce and T.

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 1.80 765.00 Review status of supplemental subpoena

productions (M&T .3), (Morgan Stanley .3),

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.10 42.50 Correspond w P. Linsey and Bank of China

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.40 170.00 Prepare for meeting with Supreme Fintech

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond w Comerica Bank regarding

supplemental documents, correspond w K.

Despins, Ch 11 Trustee/Luc A. Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 21 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 102 of

Phase ID B120 Asset Analysis and Recovery

B120 A101 200.00 0.20 40.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.30 127.50 Review and revise B. Enriquez subpoena,

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Analyze Supreme Fintech's February and

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.50 212.50 Review status of BoA productions related

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond w BoA related to amended

Despins, Ch 11 Trustee/Luc A.

B120 A103 355.00 0.30 106.50 Phone call with Attorney D. Skalka

Despins, Ch 11 Trustee/Luc A.

B120 A110 500.00 0.40 200.00 Manage data direct appearances to be

filed for all assigned cases. Despins, Ch 11 Trustee/Luc A.

B120 A105 500.00 0.20 100.00 Communicate with Attorney Linsey re

assigned adversary proceedings. Despins, Ch 11 Trustee/Luc A.

B120 A105 480.00 3.50 1,680.00 Correspond with Attorney Linsey

USCA2d--Second Circuit No. 24-1271 (0.2);

applicable local appellate rules (1.5);

No. 24-1271 (0.4); review 28 USC sec. 158 and associated case law (1.4). Despins, Ch 11 Trustee/Luc A.

B120 A105 495.00 2.20 1,089.00 Correspond with D. Carnelli regarding

sanctions appeal (0.2), review and analyze jurisdictional issues re: sanctions appeal and correspond with D. Carnelli regarding

VCTR liquidation (0.1), correspond with A.

Date: 10/15/2024 Detail Fee Task Code Billing Report Page: 22 Case 22-50073 Doc 3702 Filed 10/15/24 Entered 10/15/24 22:22:27 Page 103 of

Phase ID B120 Asset Analysis and Recovery correspond with trustee regarding progress on VCTR liquidation motion (0.3),

Blackthorn notice (0.2), final review of 15th

Despins, Ch 11 Trustee/Luc A.

B120 A105 495.00 4.60 2,277.00 Ho Wan Kwok, Debtor Correspond with K. Mitchell and K.

N. Biale regarding service of B. Enriquez

investment (0.4), correspond with A.

call on Reverence (0.3), revise motion to

Despins, Ch 11 Trustee/Luc A.

B120 A105 200.00 0.80 160.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.70 297.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A105 200.00 0.30 60.00 Draft certificate of service for 15th

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 1.00 550.00 Attend conference call with attorneys

Despins, Ch 11 Trustee/Luc A.

B120 A103 355.00 2.50 887.50 Review professional schedule of time for

Eisner (.5), Categorize time entries(.5), Draft exhibits of hours and rates of Eisner

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.30 165.00 Draft memorandum to attorney Laya

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

P B120 A105 500.00 0.80 400.00 Despins, Ch 11 Trustee/Luc A.

mediation program participation, effort to

coming weeks. Despins, Ch 11 Trustee/Luc A.

P B120 A103 480.00 5.10 2,448.00 Draft/revise memorandum regarding

appeal in USCA2d No. 24-1271 (1.3); review 4th Circuit decision from Attorney

same issue (1.6); correspond with Attorney Linsey regarding 4th Circuit decision (0.3). Despins, Ch 11 Trustee/Luc A.

P B120 A108 495.00 2.20 1,089.00 Correspond and confer with C. Fornos

revise motion regarding VCTR shares re:

shares motion (0.1), confer with T.

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.40 170.00 Draft summaries for mediation of

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.20 85.00 correspond with N. Kinsella regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.30 127.50 Review ADP production for confidentiality

Despins, Ch 11 Trustee/Luc A.

P B120 A103 480.00 2.40 1,152.00 Complete drafting memorandum

USCA2d No. 24-1271 (0.3). Despins, Ch 11 Trustee/Luc A.

P B120 A101 220.00 1.00 220.00 Confer with Attorney Skalka regarding