Guo Wengui / Miles Guo — bankruptcy case · NOTICE · ECF #3892

United States Bankruptcy Court for the District of Connecticut

## WITHDRAWAL OF CLAIM

| Debtor Name and Case Number: | HO WAN KWOK . ETAL 22-500/3 | |--------------------------------|----------------------------------------| | Creditor Name and Address: | SHUNDUW<br>38 Your & ST., CREMORNE NSW | | Court Claim Number (if known): | 0 | | Date Claim Filed: | March<br>23 2023 | | Total Amount of Claim Filed: | 2<br>\$300,000.00 |

I, the undersigned, am the above-referenced creditor, or an authorized signatory for the above-referenced creditor. I hereby withdraw the above-referenced claim and authorize the Clerk of this Court, or their duly appointed Claims Agent, to reflect this withdrawal on the official claims register for the abovereferenced Debtor.

| Print Name: | SHILL INA | | |------------------------|-----------|--| | Title (if applicable): | | |

#### DEFINITIONS

#### Debtor

The person, corporation, or other entity that has filed a bankruptcy case is called the debtor.

#### Creditor

A creditor is any person, corporation, or other entity to which the debtor owed a debt.

#### Proof of Claim

A form filed with the clerk of the bankruptcy court where the bankruptcy case was filed, to tell the bankruptey court how much the debor owed a creditor (the amount of the creditor's claim).

## ITEMS TO BE COMPLETED ON THIS WITHDRAWAL OF CLAIM

#### Court, Name of Debtor and Case Number:

Fill in the name of the federal judicial district where the bankruptey case was filed (for example, Central District of California), the name of the debtor in the bankruptcy case, and the banks of your received a notice of the case from the court, all of this information is near the top of the notice.

#### Information about Creditor:

Complete the section giving the name and address of the creditor that was listed on the previously filed Proof of Claim form.

#### Information identifying the Claim that is to be withdrawn:

Complete the section giving the court claim number, date claim was filed and total amount of claim filed to help identify the claim that is to be withdrawn.

Sign and print the name and title, if any, of the person authorized to file this withdrawal of claim (attach copy of power of attorney, if any).

This form must be filed with the clerk of the bankruptcy court where the bankruptcy case was filed or, if applicable, with their duly appointed Claims Agent as per any procedure approved by the court in the above-referenced bankruptcy proceeding.

# Case 22-50073 Doc 3892 Filed 08/09/24 Entered 12/13/24 10:34:20 Page 2 of 16

Epig Bankruptcy Solutions, LLC PO BOX 4470 Beaverton, OR 97076-4470

BAR(23) MAILID \*\*\* 000215146298 \*\*\*

Address Service Requested

Legal Documents Enclosed Please direct to the attention of the Addressee. Legal Department or President


\*\*\*\* HTT CLMLTR (MERGE2,TXNUM2) 4000000922 \*\*\*\*


UNIT 9, 38 YOUNG ST CREMORNE NSW 2090

AUSTRALIA

March 23, 2023

# ACKNOWLEDGEMENT OF RECEIPT OF PROOF OF CLAIM

This letter serves as acknowledgement that the claim identified below has been recorded by Epiq Bankruptcy Solutions, LLC, the court-approved claims agent, on the claims register in the HWK Trust case ("Acknowledgement"). The claim is also publicly available at the following website address: htt To ensure that your claim has been recorded correctly, please review the following information:

| Debtor: | HO WAN KWOK, ET AL. | | |----------------|---------------------|--| | Case Number: | 22-50073 | | | Creditor: | LI, SHUNJUN | | | Date Received: | 02/06/2023 | | | Claim Number: | 107 | |

Please note that nothing in this Acknowledgement should be construed to mean or imply that your claim is being allowed. The Debtor may elect to object to the identified claim on various grounds.

We strongly encourage you to review your submitted proof of claim image on our website at the address listed above. To find your proof of claim image, enter your name or claim number listed above in the Search Box. The PDF claim image will be accessible on the right side of the page.

WHEN REVIEWING YOUR CLAIM, PLEASE BE AWARE OF ANY PERSONALLY IDENTIFIABLE INFORMATION ( "PII") THAT YOU MAY HAVE SUBMITTED AS PART OF YOUR CLAIM. PII can include information used to distinguish or trace an individual's identity, such as a social security number, biometric records, driver's license number, account number, credit or debit card number (including any passwords, access codes, or PIN numbers), or other similar information which alone, or when combined with other personal or identifying information (such as date, place of birth, mother's maiden name etc.), is linked or traceable to a specific individual.

The Proof of Claim Form allows for redacted information. If you identify any PII in your filed claim, please contact us immediately at (646) 282-2400 or via our contact form on our website at htt and select "Submit Inquiry" in the Case Actions section.

You may also contact us by either of the methods listed above should you have any other questions.

EPIQ BANKRUPTCY SOLUTIONS, LLC

Epiq Corporate Restructuring, LLC PO Box 4470 Beaverton, OR 97076 Address Service Requested

Legal Documents Enclosed -Please direct to the attention of the Addressee, Legal Department or President


HTT SALE NOT 06-02-2023 (MERGE2,TXNUM2) \*\*\*\*\*400000922\*\*\*\*\*\* BAR(23) MAIL ID \*\*\* 000216705654 \*\*\*

LI, SHUNJUN UNIT 9, 38 YOUNG ST CREMORNE NSW 2090

AUSTRALIA

# THIS PAGE INTENTIONALLY LEFT BLANK


Case 22-50073 Doc 1859 Filed 06/02/23 Entered 06/02/23 16:29:39 Page 1 of 2

# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT

)

)

)

In re:

HO WAN KWOK, et al.,

Chapter 11 Case No. 22-50073 (JAM) (Jointly Administered)

Debtors.

Re: ECF No. 1858

# NOTICE OF HEARING ON MOTION, PURSUANT TO BANKRUPTCY CODE SECTIONS 105 AND 363, BANKRUPTCY RULES 2002, 6004(c), AND 9014, AND LOCAL RULES 6004-1 AND 6004-2, SEEKING ENTRY OF ORDER: (1) AUTHORIZING AND APPROVING SALE OF THE LADY MAY FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS, AND ENCUMBRANCES, (II) AUTHORIZING AND APPROVING PURCHASE AND SALE AGREEMENT, AND (III) GRANTING RELATED RELIEF

PLEASE TAKE NOTICE that, pursuant to D. Conn. L. Bankr. R. 6004-2(b), 9014-1(n), and Appendix N, a hearing will be held on June 27, 2023 at 12:00 p.m. (noon) and shall continue, as necessary, on June 28, 2023 at 10:00 a.m. at the United States Bankruptcy Court, 915 Lafayette Boulevard, Bridgeport, Connecticut to consider and act upon the following matter:

Motion, Pursuant To Bankruptcy Code Sections 105 And 363, Bankruptcy Rules 2002, 6004(C), And 9014, And Local Rules 6004-1 And 6004-2, Seeking Entry Of Order: (I) Authorizing And Approving Sale Of The Lady May Free And Clear Of Liens, Claims, Interests, And Encumbrances, (II) Authorizing And Approving Purchase And Sale Agreement, And (III) Granting Related Relief (the "Motion"), ECF No. 1858, filed on behalf of Mr. Luc A. Despins, in his capacity as Chapter 11 trustee for the estate of Mr. Ho Wan Kwok (the "Trustee").

In accordance with Fed. R. Bankr. P. 2002(a), 9006(d), and 9014(a)-(b), any party shall file any Objection and/or Response on or before June 23, 2023 and the Trustee shall file any Reply on or before June 26, 2023 at 12:00 p.m. (noon).

On or before June 5, 2023, the Trustee shall serve this Notice of Hearing and the Motion and any attachments thereto on parties who are required to receive notice pursuant to Fed. R. Bankr. P. 2002(a)(2) and D. Conn. L. Bankr. R. 6004-2(g), including without limitation all creditors 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).


Case 22-50073 Doc 1859 Filed 06/02/23 Entered 06/02/23 16:29:39 Page 2 of 2

all parties indicating interest in the purchase of the property to be sold, and the Trustee shall file a Certificate of Service on or before June 6, 2023 evidencing that such service was made.

In accordance with D. Coun. L. Bankr. R. 2002-1(a), 9036-1 and Appendix A, service of this Notice of Hearing shall be made via the Court's CM/ECF System upon parties who have filed appearances in these Chapter 11 cases or have otherwise consented to electronic service.

PLEASE TAKE FURTHER NOTICE that the hearing may be continued, adjourned, or canceled as appropriate without further notice.

Dated: June 2. 2023

Pietro Cicolini Clerk of Court

United States Bankruptcy Court District of Connecticut 915 Lafayette Boulevard Bridgeport, CT 06604

Tel. (203) 579-5808 VCIS\* (866) 222-8029 \* Voice Case Information Syste htt Form 112 – rms

| | CASE NO: 22-50073 | | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------| | In re:<br>Ho Wan Kwok, et al.<br>Debtor(s). | CHAPTER: 11 | | | Attorney or Party Name, Address, Telephone & FAX<br>Nos State Bar No. & Email Address:<br>Douglas S. Skalka (State Bar No. ct00616)<br>NEUBERT, PEPE & MONTEITH, P.C.<br>195 Church Street, 13th Floor<br>New Haven, Connecticut 06510<br>Tel: (203) 781-2847<br>Fax: (203) 821-2009<br>dskalka@npmlaw.com<br>Attorney for: Luc A. Despins, as Trustee for the Estate of Ho Wan<br>Kwok | | NOTICE OF PROPOSED<br>PRIVATE SALE OF ESTATE PROPERTY<br>D. CONN. BANKR. L. R. 6004-1(a) | | Rules 6004-1 and 6004-2, Seeking Entry Of Order: (1) Authorizing and Approving Sale of the Lady May Free and Clear of<br>Liens, Claims, Interests, and Encumbrances, (II) Authorizing and Approving Purchase and Sale Agreement, and (III) Granting | | Trustee's Motion, Pursuant to Bankruptcy Code Sections 105 and 363, Bankruptcy Rules 2002, 6004(c), and Local | | Related [Docket No. 1858] (the "Motion")<br>THE MOTION CAN BE VIEWED, FREE OF CHARGE, AT: http>OBJECTION(S) DUE: June 23, 2020 before 4:00 p.m. (ET). Untimely objections may not be considered.<br>Description of property to be sold (use additional page, if more space is needed): | | | | | | | | The Lady May yacht (Reg. No. 745195), which includes all gear, machinery, equipment, firel, consumables, all registered<br>tenders, toys, articles and appurtenances on board the Lady May and/or included on the Lady May's listing specification as of May 30, 2023.<br>Proposed Private Sale Information:<br>June 30, 2023<br>Date of Proposed Private Sale: | Time of Proposed Private Sale: | At or before 11:59 p.m. (ET) | | International waters off the coast of Rhode Island, United States.<br>Location of<br>Proposed Private<br>Sale: | | | | Objection Deadline and Hearing Information:<br>*Last date to file Objections to<br>June 23, 2020 before 4:00 p.m. (ET)<br>Proposed Private Sale: | * Hearing when objection filed: A hearing on any objection to the<br>Time listed in this Notice.<br>* Hearing when no objection filed: If no objection to the Notice of | Notice of Proposed Private Sale shall be held on the Hearing Date and | | * Hearing Date and Time<br>June 27, 2023 at 12:00 p.m. (ET)<br>regarding Proposed Private Sale:<br>and continuing on June 28, 2023<br>(if necessary) | the Notice of Proposed Private Sale be held on the Hearing Date and<br>Time listed in this Notice. | Proposed Private Sale is filed, the Court may require that a hearing on |

Pursuant to D. Conn. Bankr. L.R. 6004-1(a), this form is mandatory. It has been approved for use in the United States Bankruptcy Court for the District of Connecticut and will be posted by the Clerk on the Court's website for publication. Connecticut Connecticut Local Form: CTB-LF238.A1

03/2023


# Proposed Private Sale price: \$24,000,000.00

Terms and conditions of Proposed Private Sale, including, if applicable, information about how to register as a bidder:

| | Summary Description | |------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Provision | | | Parties | Seller: Luc A. Despins, solely in his capacity as chapter 11 trustee for the estate of Ho Wan Kwok (the "Trustee").<br>Buyer: Herb Chambers Yachting, LLC | | Deposit | On May 31, 2023, the Buyer paid the deposit of \$4,800,000 (20% of the Purchase Price) to the Trustee's account, as a<br>deposit toward the purchase price to be held in escrow subject to the Purchase and Sale Agreement (the<br>"PSA"). | | Survey Option;<br>Acceptance of Lady<br>May | Buyer's obligation to purchase the Lady May is subject to Buyer's satisfaction with a trial run and survey of the Lady<br>May; provided, however, that Buyer may only reject the Lady May if the surveyor (who shall be a duly qualified<br>marine surveyor) certifies in writing that it discovered defects that affect the operational integrity of the Lady May or<br>her machinery or her systems or renders the Lady May unseaworthy. The outside date for the Buyer to reject the Lady<br>May based on the survey is June 20, 2023. Whether or not the Buyer has inspected the Lady May, the Buyer will be<br>deemed to have accepted the Lady May if it fails to give timely written notice of its rejection in accordance with the<br>PSA. | | Closing | The transfer of the Lady May's ownership (the "Closing") will occur on or before June 30, 2023 (the "Closing Date").<br>The Closing will occur in international waters off the coast of Rhode Island, simultaneously with payment of all funds<br>due from the Buyer and delivery of originals of all other documents necessary for transfer of good and marketable title<br>to the Buyer.<br>At Closing, the Buyer will pay the balance of the Purchase Price (i.e., \$19,200,000) to the Trustee and the Deposit<br>will be released to the Trustee, subject to deductions the Trustee owes to the Brokers for the commission, storage,<br>insurance, repairs and/or other items (which are subject to approval of this Court). | | Sellers<br>Representations/<br>Requirements for<br>Closing | The Trustee represents and warrants that it will transfer to the Buyer good and marketable title to the Lady May, free<br>and clear of all debts, claims, maritime or common law liens, security interests, encumbrances, excise taxes, and other<br>applicable taxes, customs' duties, or tariffs due to any state, country, regulatory and/or taxing authority of any kind<br>whatsoever (collectively the "Encumbrances").<br>No less than two (2) business days before Closing, the Trustee will deliver to the Buyer (a) satisfactory evidence of<br>title, (b) proof of payment or removal of all Encumbrances (except for those encumbrances that will be paid in full at<br>closing), which proof may be the order entered by the Bankruptcy Court approving the sale of the Lady May (and<br>which order shall provide the Lady May is being sold to Buyer free and clear of any Encumbrances), and (c) copies of<br>any other documents necessary for transfer of good and marketable title to Buyer. | | Risk of Loss | The Trustee will bear the risk of loss of or damage to the Lady May prior to Closing. | | Representations and<br>Warranties | Upon Closing, the Buyer will be deemed to have accepted the Lady May in its "as is" condition, the Trustee and the<br>Brokers have given no warranty, either expressed or implied, and make no representation as to the condition of the<br>Lady May, its fitness for any particular purpose or merchantability, all of which are disclaimed. | | Bankruptcy Court<br>Approval | The PSA for the proposed sale is subject to approval of this Court. | | Additional Bids | Any interested bidders should contact the Trustee, whose contact information is included below, in connection with<br>their bids on the Lady May. |

Contact person for Proposed Private Sale (include name, address, telephone, fax and/or email address):

Luc A. Despins, Chapter 11 Trustee for the Estate of Ho Wan Kwok Paul Hastings LLP 200 Park Avenue New York, NY 10166 Tel: (212) 318-6079 Fax: (212) 230-7771 lucdespins@paulhastings.com

Date: June 2, 2023

Pursuant to D. Conn. Bankr. L.R. 6004-1(a), this form is mandatory. It has been approved for use in the United States Bankruptey Court for the District of Connecticut and will be posted by the Clerk on the Court's website for publication.

03/2023

Connecticut Local Form: CTB-LF238.A1 Page 2 Local Rule 6004-1(a) - Notice of Proposed Private Sale of Estate Property

# Pietro Cicolini

| From: | June Li <shunjunli@yahoo.com.au></shunjunli@yahoo.com.au> | |----------|-----------------------------------------------------------| | Sent: | Friday, August 9, 2024 1:22 AM | | To: | Zahm, Geoff | | Subject: | Fwd: Ho Wan Kwok, et al. – Request for Information |

You don't often get email from shunjunli@yahoo.com.au. Learn why this is important

CAUTION: This email originated from outside of Epiq. Do not click links or open attachments unless you recognize the sender and know the content is safe. Report phishing by using the "Phish Alert Report" button above.

Hi again Geoff.

l just realised I forgot to attach those forms as soon as I hit the send button.

Here they are.

Cheers, Shunjun Li

Begin forwarded message:

From: June Li <shunjunli@yahoo.com.au> Date: 9 August 2024 at 3:18:09 PM AEST To: "Zahm. Geoff" <gzahm@epigglobal.com> Subject: Re: Ho Wan Kwok, et al. - Request for Information

Hi, Geoff.

Thanks for sending the form through.

Please find attached forms for your information to process this withdrawal. The reason that I put question mark for question "total amount of claim" is because I couldn't find that copy of document after moving house. So I can only put \$300K from my memory but I manage to find documents that were sent from court to prove I had filed this claim last vear.

So I do have trouble finding the actual claim amount. I am wondering if you can identify my filed documents and tell me the number so that I can resubmit the form to you again with the correct claim amount.

Please let me know if this can be done. Thanks for your assistance in advance.

Warm regards, Shunjun Li

On 6 Aug 2024, at 2:04 AM, Zahm, Geoff <gzahm@epigglobal.com> wrote:

Hello, Please fill out the attached withdrawal form if you would like to withdraw your claim. Thanks, Geoff Geoff Zahm Office: (646) 282-2599 Mobile: (917) 363-1319

From: notification <notification@epigglobal.com> Sent: Saturday, August 3, 2024 7:05 AM To: DL-EBS-ProdDevTeam <EBS-ProdDevTeam@epigglobal.com> Subject: Ho Wan Kwok, et al. - Request for Information Name: Li, Shunjun Email: shunjunli@yahoo.com.au Phone: 0402307704 Address One: Address Two:

City: Sydney Australia, State: --, Zip Code:

Organization:

Inquiry: Dear Sir or madam: RE: Claim number: 107 I had filed this claim on 02/06/2023 as individual. After serious conderation, I decided to withdraw my claim. Can you guide me through how to do this please? Thanks for your assistance in advance. Warm regards, Shunjun Li

This communication (including any attachment(s)) is intended solely for the recipient(s) named above and may contain information that is confidential, privileged or legally protected. Any unauthorized use or dissemination of this communication is strictly prohibited. If you have received this communication in error, please immediately notify the sender by return e-mail message and delete all copies of the original communication to include any copy that may reside in your sent box. Thank you for your cooperation.

<Claim Withdrawal Form.pdf>

Case 22-50073 Doc 3892 Filed 08/09/24 Entered 12/13/24 10:34:20 Page 11 of 16


Epiq Bankruptcy Solutions, LLC PO BOX 4470 Beaverton, OR 97076-4470

Address Service Requested

# BAR(23) MAILID \*\*\* 000215146298 \*\*\* LI, SHUNJUN UNIT 9, 38 YOUNG ST CREMORNE NSW 2090 AUSTRALIA

Epiq Corporate Restructuring, LLC PO Box 4470 Beaverton, OR 97076 Address Service Requested


LI. SHUNJUN UNIT 9, 38 YOUNG ST CREMORNE NSW 2090

AUSTRALIA


Case 22-50073 Doc 3892 Filed 08/09/24 Entered 12/13/24 10:34:20 Page 15 of 16


# Case 22-50073

all parties indicating i a Certificate of Servic

In accordance with D Notice of Hearing sha appearances in these (

PLEASE TAKE FU canceled as appropria