Guo Wengui / Miles Guo — bankruptcy case · ECF #3931

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

---------------------------------------------------------X MOTION FOR ADMISSION PRO HAC VICE OF STUART L. KOSSAR

Pursuant to Local Rule of Civil Procedures 83.1(d) of the United States District Court for the District of Connecticut, incorporated herein by Local Rule of Bankruptcy Procedure 1001-1, the undersigned, a member of the Bar of this Court and partner of the law firm Norris McLaughlin, P..A., respectfully moves that the Court admit attorney Stuart L. Kossar, a member of the Bar of the State of New York, the United States District Court of the Southern District of New York, and the United States District Court of the Eastern District of New York, pro hac vice to represent: (i) Flat Rate Movers, Ltd. in the above captioned Chapter 11 bankruptcy case and in the related adversary proceeding Luc A. Despins, Chapter 11 Trustee v. Flat Rate Movers, Ltd., Adv. Pro. No. 24-05141 and (ii) Norris McLaughlin, P..A in the above captioned Chapter 11 bankruptcy case and in the related adversary proceeding Luc A. Despins, Chapter 11 Trustee v. Norris McLaughlin, P.A., Adv. Pro. No. 24-05317, and in support represents the following:

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).

1. The primary office of Attorney Kossar is Norris McLaughlin, P.A., 7 Times Square, 21st Floor, New York 10036. His telephone number is (917) 369-8822; his fax number is (212) 808-0844; and his email address is [slkossar@norris-law.com].

2. Attorney Kossar is a member in good standing in the states and jurisdictions set forth in his declaration, attached as Exhibit A.

3. To best of my knowledge and belief, Attorney Kossar is a member in good standing of the courts listed in his declaration, and he has not been the petitioner to, has not been denied admission to, been disciplined by, resigned from, surrendered a license to practice before, or withdrawn an application for admission to practice while facing a disciplinary complaint before, this Court or any other court.

4. To best of my knowledge and belief, Attorney Kossar has reviewed and is familiar with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the District of Connecticut, the Local Rules of the Bankruptcy Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct.

5. Attorney Kossar has submitted the filing fee of \$200.00 with this motion for pro hac vice admission.

6. Service of all papers directed to Flat Rate Movers, Ltd. or Norris McLaughlin, P.A. may be made upon the undersigned, pursuant to Rule 83.1(c) of the Local Rules of Civil Procedure for the United States District Court for the District of Connecticut. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

Dated: January 2, 2025 NORRIS McLAUGHLIN, P.A. Bridgewater, New Jersey

By: /s/ James J. Costello Jr.

James J. Costello Jr. Esq. (ct. 309468) 400 Crossing Blvd, 8th Floor Bridgewater, NJ 08807-5933 (908) 252-4315 [jjcostellojr@norris-law.com]

> Attorneys for Flat Rate Movers, Ltd & Norris McLaughlin, P.A.

I hereby certify that the foregoing Motion for Admission Pro Hac Vice of Stuart L. Kossar was filed electronically on January 2, 2025. Notice of this filing will be sent by email to all parties registered for electronic service in this proceeding through the Court's CM/ECF system.

> By: /s/ James J. Costello Jr. James J. Costello Jr. Esq.

Case 22-50073 Doc 3931 Filed 01/02/25 Entered 01/02/25 12:23:16 Page 5 of 12

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

DECLARATION OF STUART L. KOSSAR IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE

I, Stuart L. Kossar, being of full age and having been duly sworn according to law, state the following:

1. I am an attorney and associate at the firm Norris McLaughlin, P.A., with an address located at 7 Times Square, 21st Floor, New York, NY 10036. My firm telephone number is 917-369-8822; my fax number is 212-808-0844; and my email address is [slkossar@norris][law.com.]

2. I submit this declaration in support of the motion for my admission pro hac vice as counsel for: (i) Flat Rate Movers, Ltd. in the above captioned Chapter 11 bankruptcy case and in the related adversary proceeding Luc A. Despins, Chapter 11 Trustee v. Flat Rate Movers, Ltd., Adv. Pro. No. 24-05141 and (ii) Norris McLaughlin, P..A in the above captioned Chapter 11 bankruptcy case and in the related adversary proceeding Luc A. Despins, Chapter 11 Trustee v. Norris McLaughlin, P.A., Adv. Pro. No. 24-05317.

2 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).

3. Pursuant to D. Conn. L. Civ. 83(d), I designate the District of Connecticut as the forum for any resolution of any dispute arising out of my admission.

4. I am member in good standing of the Bar of the State of New York (Bar No. 4559662), the United States District Court of the Southern District of New York (Bar No. SK1414), and the United States District Court of the Eastern District of New York (Bar No. SK1414) as shown by the certificates of good standing annexed hereto.

5. I have no disciplinary complaints, and I have not been denied admission to, been disciplined by, resigned from, surrendered my license to practice before, or withdrawn an application for admission to practice before this Court or any other court.

6. I have read and am familiar with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the District of Connecticut, the Local Rule of the Bankruptcy Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct, and will abide by and comply with the substantive and procedural requirements of the local rules and the administrative orders of this Court.

7. I hereby designate my sponsoring attorney James J. Costello, Jr. (Federal Bar No. ct309468) of Norris McLaughlin, P.A. as my agent for service of process and the District of Connecticut as the forum for the resolution of any dispute arising out of my admission pro hac vice in the above-captioned chapter 11 case and related cases.

8. I declare under penalty of perjury that the foregoing is true and accurate. Subscribed and sworn this 2nd day of January 2025 at New York, NY.

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE OF STUART L. KOSSAR

AND NOW, upon consideration of the Motion of James J. Costello, Jr. for Admission Pro

Hac Vice of Stuart L. Kossar (the "Motion"), and any and all responses thereto, it is hereby,

ORDERED that the Motion is GRANTED and Stuart L. Kossar is admitted pro hac vice to represent: (i) Flat Rate Movers, Ltd. in the above captioned Chapter 11 bankruptcy case and in the related adversary proceeding Luc A. Despins, Chapter 11 Trustee v. Flat Rate Movers, Ltd., Adv. Pro. No. 24-05141 and (ii) Norris McLaughlin, P..A in the above captioned Chapter 11 bankruptcy case and in the related adversary proceeding Luc A. Despins, Chapter 11 Trustee v. Norris McLaughlin, P.A., Adv. Pro. No. 24-05317; and it is further

ORDERED that James J. Costello, Jr. will receive service on behalf of Attorney Kossar in accordance with D. Conn. L. Civ. R. 83.1(c), as incorporated by D. Conn. LBR 9083-3.

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 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).

Appellate Division of the Supreme Court of the State of New York Second Judicial Department

I, Darrell M. Joseph, Clerk of the Appellate Division of the Supreme Court of the State of New York, Second Judicial Department, do hereby certify that

was duly licensed and admitted to practice as an Attorney and Counselor at Law in all the courts of this State on March 5, 2008, has duly taken and subscribed the oath of office prescribed by law, has been enrolled in the Roll of Attorneys and Counselors at Law on file in this office, is duly registered with the Office of Court Administration, and according to the records of this Court is currently in good standing as an Attorney and Counselor-at-Law.

In Witness Whereof, I have hereunto set my hand in the City of Brooklyn on December 17, 2024.

Appellate Dibision Supreme Court of the State of Bew Bork Second Judicial Department 45 Montoe Blace Brooklpn, B. B. 11201 (718) 875-1300

KENNETH BAND MELISSA KRAKOWSKI DEPUTY Clerks

WENDY STYNES LAUREN G. DOME BRIAN E. KENNEDY ASSOCIATE DEPUTY CLERKS

An attorney admitted to practice by this Court may request a certificate of good standing, which is the only official document this Court issues certifying to an attorney's admission and good standing.

An attorney's registration status, date of admission and disciplinary history may be viewed through the attorney search feature on the website of the Unified Court System.

New York State does not register attorneys as active or inactive.

An attorney may request a disciplinary history letter from the Attorney Grievance Committee of the Second Judicial Department.

Bar examination history is available from the New York State Board of Law Examiners.

Instructions, forms and links are available on this Court's website.

AO 136 (Rev. 10/13) Certificate of Good Standing

ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘ ______________________________________________________________________________________________________________________________________________________________________________

certify that Stuart Lawrence Kossar ______________________________________________________________________________________________________________________________________________________________________________ SK1414 was duly admitted to practice in this Court on and is in good standing as a member of the Bar of this Court.

(Location) ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘ on 12/17/2024

Case 22-50073 Doc 3931 Filed 01/02/25 Entered 01/02/25 12:23:16 Page 12 of 12 United States District Court Southern District of Reto Dork

I, Tammi M. Hellwig, Clerk of Court, Certify that

was duly admitted to practice in the Court on

and is in good standing as a member of the Bar of this Court