Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3948

## **UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

) Debtors.¹ )

In re: ) Chapter 11

HO WAN KWOK, *et al.*, ) Case No. 22-50073 (JAM) ) (Jointly Administered)

## **MOTION OF ZETA GLOBAL CORP. TO EXCUSE LOCAL COUNSEL FROM ATTENDANCE AT JANUARY 15, 2025 HEARING**

)

Zeta Global Corp. respectfully moves for an order excusing its undersigned local counsel from attendance at the hearing on Motions to Dismiss and Motions for Judgment on the Pleadings (the "Motions") scheduled for Wednesday, January 15, 2025, at 10:00 a.m. before the Honorable Julie A. Manning, United States Bankruptcy Judge (the "Hearing"). In support of the motion, Zeta Global Corp. respectfully states:

1. Zeta Global Corp. is the defendant in an adversary proceeding captioned *Luc A. Despins, Chapter 11 Trustee v. Zeta Global Corp.*, Adv. Proc. No. 24-05092. In that adversary proceeding, Zeta Global Corp. has filed a motion for judgment on the pleadings [Adv. Proc. ECF No. 21] in accordance with the Court's Order Further Amending Avoidance Action Procedures Order and Scheduling Joint Briefing of Motions to Dismiss and Motions for Judgment on the Pleadings, entered in these chapter 11 cases on September 25, 2024 [ECF No. 3577].

2. On November 27, 2024, the Court entered a scheduling order scheduling the Hearing [Bankr. ECF No. 3857].

¹ The Debtors 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. Zeta Global Corp. is represented in the adversary proceeding by DLA Piper LLP (US) through John J. Clarke, Jr. and C. Kevin Kobbe, who are both members of the firm. Mr. Clarke is a member of the bar of this Court and is acting as local counsel. Mr. Kobbe is a visiting lawyer who has been admitted *pro hac vice* and is acting as lead counsel for Zeta Global Corp. in these matters.

4. Mr. Kobbe will be attending the Hearing in person, in accordance with the Court's scheduling order. Mr. Clarke is scheduled to be out of the country on the date of the Hearing and therefore will be unable to attend.

In accordance with Local Bankr. R. 9083-1 and Local R. 83-1(e)(2), Zeta Global Corp. respectfully requests that its local counsel, Mr. Clarke, be excused from attendance at the Hearing and that its lead counsel, Mr. Kobbe, be permitted to speak at the Hearing (solely to the extent necessary) without being accompanied by local counsel at the Hearing.

Dated: New York, New York January 8, 2025

DLA PIPER LLP (US)

By: /s/ John J. Clarke, Jr. John J. Clarke, Jr. (ct31251) john.clarke@us.dlapiper.com

1251 Avenue of the Americas New York, New York 10020 (212) 335-4500

and

C. Kevin Kobbe kevin.kobbe@us.dlapiper.com 650 South Exeter Street, Suite 1100 Baltimore, Maryland 21202 (410) 580-4189

*Counsel for Zeta Global Corp.*

## CERTIFICATE OF SERVICE

I am counsel for the defendant Zeta Global Corp. in these proceedings. I certify that on January 8, 2025, I caused a copy of the foregoing to be filed electronically using the Court's electronic case filing system, which will provide notice of this filing electronically to all parties who have appeared in the chapter 11 case and in the adversary proceeding.

> /s/ John J. Clarke, Jr. John J. Clarke, Jr. (ct31251)