Guo Wengui / Miles Guo — bankruptcy case · MOTION · ECF #3761

## UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT

In re:

HO WAN KWOK, et al.,

Chapter 11

Case No. 22-50073 (JAM)

Debtors.

(Jointly Administered)

## MOTION TO PERMIT COUNSEL FOR AMERICAN EXPRESS COMPANY TO APPEAR REMOTELY AT THE HEARING ON NOVEMBER 5, 2024

American Express Company ("American Express") moves to allow its counsel, Darryl S. Laddin and Frank N. White, to appear remotely via the Court's Zoom platform -solely to listen and monitor any developments -- at the hearing set for November 5, 2024 at 1:00 p.m. E.T. on the Trustee's Motion to Further Amend Avoidance and Mediation Procedures [ECF No. 3659].

1. chapter 11 trustee Luc A. Despins (the "Trustee"). See Adv. Proc. No. 24-05077.

2. The Trustee's Motion seeks an amendment of the Court's avoidance action and mediation procedures to effectuate a temporary stay of discovery in the Trustee's numerous avoidance actions, pending completion of joint briefing and the Court's ruling on various, potentially dispositive issues that are common to a large number of those cases.

3. Accordingly, the November 5, 2024 hearing is likely to address or involve discussion of scheduling and other issues bearing directly on the Trustee's adversary against American Express, among others, or in which American Express otherwise has a decided interest and needs to be aware.

4. J Mr. Laddin and Mr. White reside and work in Atlanta, Georgia. They wish to appear at the November 5 hearing, but solely to listen into and monitor the proceedings. Given the time and expense needed to travel to Bridgeport, CT, they respectfully request that the Court permit them to participate via the Court's Zoom platform.

WHEREFORE, American Express respectfully requests that the Court allow Mr. Laddin and/or Mr. White to participate remotely via the Court's Zoom platform for the November 5, 2024 hearing.

Dated: October 30, 2024

LAW OFFICES OF RONALD I. CHORCHES, LLC By: /s/ Ronald I. Chorches Ronald I. Chorches, Esq. Fed Bar #ct08720 Law Offices of Ronald I. Chorches, LLC 82 Wolcott Hill Rd Wethersfield, CT 06109 Tel: (860) 563-3955/Fax: (860) 513-1577 Email: ronchorcheslaw@sbcglobal.net

ARNALL GOLDEN GREGORY LLP Darryl S. Laddin Frank N. White 171 17th Street, N.W., Suite 2100 Atlanta, GA 30363-1031 Telephone: (404) 873-8500 Fax: (404) 873-8121 darry1.laddin@agg.com frank.white@agg.com

Attorneys for American Express Company