Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3919

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., :

Debtors.1 :

MONTHLY FEE STATEMENT OF KROLL, LLC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM NOVEMBER 1, 2024 THROUGH NOVEMBER 30, 2024

In accordance with the Order Establishing Procedures for Interim Compensation and

Reimbursement of Expenses for Retained Professionals, dated August 18, 2023 [Docket No.

2094] (the "Interim Compensation Order"),2 Kroll, LLC ("Kroll") hereby submits this monthly

statement (the "Monthly Fee Statement") seeking compensation for services rendered and

reimbursement of expenses incurred as forensic investigators to Luc A. Despins, in his capacity

as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok, for

the period from November 1, 2024 through and including November 30, 2024 (the "Fee

Period"). By this Monthly Fee Statement, Kroll respectfully requests payment of 80% of all fees

and 100% of all expenses actually and necessarily incurred for services rendered during the Fee

Period, in the amounts of \$34,413.24 and \$3,619.40, respectively.

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

2 Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Interim Compensation Order.

1. Attached hereto as Exhibit A is a timekeeper summary that includes the name, title, service line, standard rate, discounted rate, total hours, and total fees earned for each Kroll individual who provided services during the Fee Period. The rates charged by Kroll for services rendered to the Trustee are discounted per the engagement letter to the rates that Kroll charges generally for professional services rendered to its non-bankruptcy clients.

2. Attached hereto as Exhibit B is a summary of Kroll's services rendered and compensation sought for the Fee Period organized by Project Category.

3. Attached hereto as Exhibit C is a summary of Kroll's services rendered and compensation sought for the Fee Period organized by Matter ID.

4. Attached hereto as Exhibit D is a summary of Kroll's expenses incurred and reimbursement sought for the Fee Period organized by Expense Type.

5. Attached hereto as Exhibit E are Kroll's fee statements for services provided during the Fee Period.

6. Notice of this Monthly Fee Statement will be given by email on the Notice Parties: (i) Luc A. Despins, as chapter 11 trustee for the estate of Ho Wan Kwok (lucdespins@paulhastings.com); (ii) Counsel for the Trustee, (x) Paul Hastings LLP, 200 Park Avenue, New York, New York 10166 (Attn: G. Alexander Bongartz (alexbongartz@paulhastings.com) and Douglass Barron (douglassbarron@paulhastings.com)) and (y) Neubert, Pepe & Monteith, P.C., 195 Church Street, 13th Floor, New Haven, Connecticut 06510 (Attn: Douglas S. Skalka (dskalka@npmlaw.com) and Patrick R. Linsey (plinsey@npmlaw.com)); (iii) the Office of The United States Trustee, Giaimo Federal Building, 150 Court Street, Room 302, New Haven, Connecticut 06510 (Attn: Holley L. Claiborn

(holley.l.claiborn@usdoj.gov)); (iv) counsel for the Official Committee of Unsecured Creditors, Pullman & Comley, LLC, 850 Main Street, 8th Floor, PO Box 7006, Bridgeport, Connecticut 06601-7006 (Attn: Irve J. Goldman (igoldman@pullcom.com); and (v) counsel for Pacific Alliance Asia Opportunity Fund L.P., O'Melveny & Myers LLP, 7 Times Square, New York, New York 10036 (Attn: Peter Friedman (pfriedman@omm.com) and Stuart M. Sarnoff (ssarnoff@omm.com) (collectively, the "Notice Parties").

7. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Kroll (Attn: Allen Pfeiffer (allen.pfeiffer@kroll.com) and (ii) the Notice Parties by email no later than January 9, 2025 at 4:00 p.m. (prevailing Eastern Time) (the "Objection Deadline"), setting forth the nature of the objection and the specific amount of fees or expenses at issue.

8. If no objections to this Monthly Fee Statement are filed and received on or before the Objection Deadline, the estate shall promptly pay Kroll 80% of the fees and 100% of the expenses identified in this Monthly Fee Statement.

9. To the extent that an objection to this Monthly Fee Statement is filed and received on or before the Objection Deadline, the estate shall withhold payment of that portion of this Monthly Fee Statement to which the objection is directed and promptly pay the remainder of the fees and expenses in the percentages set forth above. To the extent such an objection is not resolved, it shall be preserved and scheduled for consideration at the next interim fee application hearing.

By:/s/ Allen Pfeiffer Allen Pfeiffer KROLL, LLC 55 East 52nd Street, Floor 17 New York, New York 10055 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al.,3 : :

Debtors. :

The undersigned hereby certifies that on December 19, 2024, the foregoing Monthly Fee Statement was electronically filed. In addition, a copy of the Monthly Fee Statement was served by email on the Notice Parties. Parties may access this filing through the Court's CM/ECF system.

Dated: December 19, 2024 By: /s/ G. Alexander Bongartz

New York, New York G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6000 alexbongartz@paulhastings.com

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

Time Period: November 1-30, 2024.

Timekeeper Title Service Line Standard Discounted Total Total Fees

Parizek, Pam Managing Director Forensic Investigations \$ 890 \$ 712 1.5 \$

Barker, James Associate Managing Forensic Investigations \$ 710 \$ 639 5.5 \$

Lazarus, Jordan Senior Manager Forensic Investigations \$ 575 \$ 518 14.1 \$

Lomas, Adam Senior Manager Forensic Investigations \$ 575 \$ 518 46.4 \$

Levenson, Patrick Associate Manager Forensic Investigations \$ 420 \$ 378 3.8 \$

Spier, Tre Research Analyst Forensic Investigations \$ 245 \$ 221 25.8 \$

Total Hours and Fees:

Blended Hourly Rate:

U.S. Trustee Task Code and Project Category Hours Billed Fees Billed

B160 Fee/Employment Applications 5.4 S 3.086.25

B181 Preference Analysis and Recovery Actions - S B182 Post-Petition Transfers and Recovery Actions S B190 Other Contested Matters (excl. assumption/reject 69

00001 General Debtor Representation 5.4 S 3,086.25 00002 Asset Recovery Investigation and Litigation 91.7 ಲ್ಲಿ 39,930.30

00004 Bravo Luck Adversary Proceeding ಕಿ

00006 SN Apartment Adversary Proceeding S 00007 Greenwich Land Adversary Proceeding S

00010 Interpleader Adversary Proceeding S

00012 Golden Spring Adversary Proceeding S

00015 Lamp Capital Adversary Proceeding S

00017 Rule of Law Adversary Proceeding S

00019 Leading Shine Adversary Proceeding ಕಿ

Expense Category Matter ID Task Code Expense Amount

November Asset Recovery Investigation and Litigation Asset Analysis and Recovery Valid8 Charges General Debtor Representation Case Administration 3,419.40

Time Period: November 1-30, 2024. Timekeeper Date Matter Task Narrative Hours Amount

Lazarus, Jordan 11/1/2024 Asset Recovery Investigations Correspondence with NPM Law [K. 0.3 \$ 155.25 Investigation and Mitchell], A. Lomas and Paul Hastings Litigation re: new document productions from

related matters. Parizek, Pam 11/1/2024 General Debtor Fee/Employment Call with H. Claiborn and Paul Hastings 0.5 \$ 356.00 Representation Applications [A. Bongart] re: Kroll expenses, [.5] Spier, Tre 11/1/2024 Asset Recovery Investigations Review up supplemental document 1.5 \$ 330.75

Litigation related update of inventory of Debtor related bank accounts. Levenson, Patrick 11/1/2024 Asset Recovery Investigations Conducted targeted searches related to 2.0 \$ 756.00 Investigation and ownership.

Asset Recovery Investigations Prepare schedule of transfers involving 4.8 \$ 2,484.00 Investigation and parties purportedly contributing to

email to Paul Hastings [L. Song]. Lomas, Adam 11/4/2024 Asset Recovery Investigations Revisions to schedule of 1.3 \$ 672.75 Investigation and transaction activity after Litigation compose related email to Paul Hastings [N. Bassett]. Lomas, Adam 11/4/2024 Asset Recovery Investigations Respond to inquiry from NPM Law [P. 0.5 \$ 258.75 Investigation and Linsey] re: transfers to certain parties Litigation purportedly contributing to Kwok's

Investigation and Investigations Upload of bank statements into bank statement analysis tool. 0.8 \$ 414.00

Lomas, Adam 11/4/2024 Asset Recovery Investigations Review and analysis of additional 1.9 \$ 983.25

master transaction file. Lomas, Adam 11/4/2024 Asset Recovery Investigations Review of additional documents 1.4 \$ 724.50

Litigation update of inventory of Debtor-related bank accounts. Spier, Tre 11/4/2024 Asset Recovery Investigations Prepare summary schedule of transaction 0.5 \$ 110.25

Levenson, Patrick 11/5/2024 Asset Recovery Investigations Conducted

Levenson, Patrick 11/5/2024 Asset Recovery Investigation and Investigations Internal meetings and calls. 0.3 \$ 113.40

Lomas, Adam 11/5/2024 Asset Recovery Investigations Review and analysis of 3.4 \$ 1,759.50

Litigation transactions; related updates to master transaction file.

Timekeeper Date Matter Task Narrative Hours Amount

Litigation Investigations Review and analysis of

transactions; related updates to master 0.2 \$

transaction file. Lazarus, Jordan 11/6/2024 General Debtor

Applications Prepare October 2024 Monthly Fee

Lazarus, Jordan 11/6/2024 Asset Recovery

Litigation Investigations Correspondence with NPM Law [P.

re:

Lazarus, Jordan 11/6/2024 Asset Recovery

Litigation Investigations Analysis of supplemental

Levenson, Patrick 11/7/2024 Asset Recovery

Litigation Investigations Respond to inquiry from NPM Law [K.Mitchell and P. Linsey] re:

Lazarus, Jordan 11/7/2024 Asset Recovery

Litigation Investigations Analysis and related correspondence with NPM Law [P. Linsey] re:

Lazarus, Jordan 11/7/2024 Asset Recovery

Litigation Investigations Analysis of supplemental

Lazarus, Jordan 11/7/2024 General Debtor

Applications Prepare October 2024 Monthly Fee

Lazarus, Jordan 11/8/2024 Asset Recovery

Litigation Investigations Analysis of supplemental

Litigation Investigations Respond to inquiry from NPM Law [K.

Litigation Investigations Review of supplemental document

Litigation Investigations Review of supplemental document

Litigation Investigations Staff supervision re: review and analysis

Bank statements; update documents reviewed inventory. 4.3 \$

Litigation Investigations Review of supplemental document

Bank statements; update documents reviewed inventory. 2.5 \$

Timekeeper Date Matter Task Narrative Hours Amount

transactions into master transaction file. 0.4 \$

Litigation Investigations Review and analysis of

Lazarus, Jordan 11/12/2024 Asset Recovery

Litigation Investigations Analysis of newly produced documents re:

Litigation Investigations Review of additional documents

related update to internal Kroll team re:

Barker, James 11/12/2024 Asset Recovery

Litigation Investigations Upload of bank statements into bank

Lazarus, Jordan 11/12/2024 Asset Recovery

Litigation Investigations Review correspondence from NPM Law

Litigation Investigations Review and analysis of

updates to master transaction file. 2.6 \$

Bank statements; update documents reviewed inventory. 5.1 \$

Litigation Investigations Review and analysis of

Litigation Investigations Prepare schedule of transaction activity

Litigation Investigations Review and analysis of

Barker, James 11/13/2024 Asset Recovery

from A.

Litigation Investigations Review and analysis of

Litigation Investigations Prepare schedule of transaction activity

Litigation Investigations Prepare schedule of

Timekeeper Date Matter Task Narrative Hours Amount

Litigation Investigations Compose email to J. Barker re: 0.3 \$

Litigation Investigations Prepare schedule of transaction activity

Barker, James 11/13/2024 Asset Recovery

Litigation Investigations Internal team meeting with P.Levenson

Litigation Investigations Prepare schedule of

payments, and bank transactions. 6.5 \$

Litigation Investigations Prepare schedule of prepetition transfers

Lazarus, Jordan 11/14/2024 Asset Recovery

Litigation Investigations Review correspondence from Kroll team re:

Litigation Investigations Summarize connected set of transfers

Litigation Investigations Meeting re:

Hastings [L. Despins, N. Bassett, D. Barron, and L. Song]; NPM Law [P.

Barker, James 11/14/2024 Asset Recovery

Litigation Investigations Meeting with A. Lomas and Paul Hastings [L. Despins, N. Bassett, D. Barron, and L. Song]; NPM Law [P. Linsey]; re:

Barker, James 11/14/2024 Asset Recovery

Litigation Investigations Meeting with client or counsel 1.0 \$

Litigation Investigations Respond to inquiry from Paul Hastings

payments, and/or bank transactions;

email to Paul Hastings [L. Song and D.

Litigation Investigations Preliminary review of document

instructions to staff [T. Spier] re: review

Timekeeper Date Matter Task Narrative Hours Amount

Litigation Investigations Review of document productions from

Lazarus, Jordan 11/19/2024 Asset Recovery

Litigation Investigations Prepare schedule of transfers to

[P. Linsey] re: related matters. 0.5 \$

Lazarus, Jordan 11/21/2024 Asset Recovery

Litigation Investigations Compile supporting documentation for

correspondence with NPM Law [K.

Litigation Investigations Staff supervision re: review of

Lazarus, Jordan 11/22/2024 Asset Recovery

Litigation Investigations Compile supporting documentation for

correspondence with NPM Law [K.

Litigation Investigations Respond to email inquiries from NPM

documents evidencing transfers to 0.2 \$

Litigation Investigations Review and analysis of Inc bank account transactions; related updates to master transaction file. 0.6 \$

Litigation Investigations Review and analysis of

Litigation Investigations Instructions to T. Spier re: review and

Litigation Investigations Review and analysis of

Applications Review October 2024 fee statement [1.0]. 1.0 \$

Litigation Investigations Respond to inquiry from NPM Law [K.

Lazarus, Jordan 11/26/2024 General Debtor

Applications Finalize October 2024 Monthly Fee

Timekeeper Date Matter Task Narrative Hours Amount

Litigation Investigations Meeting re:

with Paul Hastings [L. Despins, N. Bassett, D. Barron, and L. Song]; NPM Law [P. Linsey and K. Mitchell]; and P. Parizek, J. Barker, and

Litigation Investigations Prepare schedule of sources and uses of

LLC;

Lazarus, Jordan 11/27/2024 Asset Recovery

Litigation Investigations Call with A. Lomas, P. Parizek, J. Barker, Paul Hastings [L. Despins, N.

Law [P. Linsey and K. Mitchell] re:

Litigation Investigations Prepare schedule of updated sources and

Litigation Investigations Review and analysis of

updates to master transaction file. 0.9 \$ 465.75

Litigation Investigations Review and analysis of LLC bank transactions; related updates to master transaction file. 1.8 \$ 931.50 Total Hours and Amount: 97.1 \$ 43,016.55