Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3961

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

-------------------------------------------------------------- x

In re: :

HO WAN KWOK, et al., :

Debtors. :

MONTHLY FEE STATEMENT OF KOBRE & KIM (GCC) LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM NOVEMBER 18, 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] Kobre & Kim (GCC) LLP ("Kobre & Kim") hereby

submits this monthly statement (the "Monthly Fee Statement") seeking compensation for

services rendered and reimbursement of expenses incurred as special counsel in the United Arab

Emirates 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 18, 2024 through and

including November 30, 2024 (the "Fee Period"). By this Monthly Fee Statement, Kobre & Kim

respectfully requests payment of 80% of all fees and 100% of all expenses actually 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 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.

necessarily incurred for services rendered during the Fee Period, in the amounts of \$74,446.40 and \$420.19, respectively.

1. Attached hereto as Exhibit A is a timekeeper summary that includes the position, hours, rate, and total fees earned for each Kobre & Kim individual who provided services during the Fee Period.

2. Attached hereto as Exhibit B is Kobre & Kim's fee statement for services provided during the Fee Period.

3. 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").

4. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Kobre & Kim (Attn: Paul Hughes (Paul.Hughes@kobrekim.com) and (ii) the Notice Parties by email no later than January 31, 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.

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

6. 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:

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

HO WAN KWOK, et al.,1 Case No. 22-50073 (JAM)

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

Dated: Januaiy 10, 2025 New York, New York By: Isl G. Alexander Bongartz G. Alexander Bongaiiz (admitted pro hac vice) PAUL HASTINGS LLP 200 Pai·k A venue New York, New York 10166 (212) 318-6000 alexbongaiiz@paulhastings.com

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 Co1poration. The mailing address for the Trustee, Genever Holdings LLC, and Genever Holdings Co1poration is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Tmstee for the Estate of Ho Wan Kwok (solely for pmposes of notices and communications).

Litigation Assistant 1.0 450.00 450.00

Date/Tkpr Description of Work Rate Hours Amount

PRH Liaise with Nada Oteifi regarding documents received from Paul Hastings and consider next steps. \$1,875.00 0.5 \$937.50 PRH Call Emily Beirne and Nada Oteifi regarding next

PRH Reviewing Kroll Report and structure chart. 1,875.00 0.4 750.00 ERB Consider initial documents sent by client, discuss next steps with Paul Hughes and Nada Oteifi. 1,300.00 0.6 780.00 ERB Consider initial documents provided by Luc Despins

ERB Consider issues of local attorney involvement

FRB Review email update to client. 1,300.00 0.2 260.00 NAE Review case documents provided by client. 1,050.00 1.3 1,365.00

PRH Liaise with Emily Beime and Nada Oteifi regarding strategic next steps on matter and updating client. 1,875.00 0.4 750.00 NAE Read and analyse documents received from the client. 1,050.00 3.0 3,150.00 NAE Confer with Emily Beirne on UAE strategies. 1,050.00 0.3 315.00

PRH Liaise with Nada Oteifi and Emily Beirne, review and approve email out. 1,875.00 0.4 750.00 PRH Further changes and approving email out to client. 1,875.00 0.2 375.00 PRH Review client response, liaise Emily Beirne and Nada Oteifi, amend and approve response. 1,875.00 0.4 750.00 PRH Liaise with team regarding Analyst engagement and instructions and further communications client. 0.4 750.00 FIRR Consider issues of 1,300.00 1.3 1,690.00 discuss same with Nada Oteifi. ERB Review update email to client. 1.300.00 0.2 260.00

Luc Despins Invoice No. 471134 December 30, 2024 PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Rate Hours Amount

NAE Attention to potential strategies in the UAE and discuss with Emily Beirne. 1,050.00 0.5 525.00 NAE Review case documents and attention to 1,050.00 1.0 1,050.00

NAE Liaise with team to progress in 1,050.00 0.3 315.00 NAE Attention and respond to client queries. 1,050.00 0.4 420.00 NAE Draft client update note. 1,050.00 0.8 840.00

ERB Consider strategy and issues of 1,300.00 0.6 780.00 ERB Consider issues of 1,300.00 0.7 910.00

NAE Attention to client's response and queries. 1,050.00 0.2 210.00

PRH Review emails x 2 from Paul Hastings and confer

PRH Call with Emily Beirne and Nada Oteifi regarding next steps on strategy and follow up. 1,875.00 0.7 1,312.50 PRH Review approve and comment on email to Paul

materials sent by Paul Hastings (1.2). Analysis

NAE Confer with team on strategy and immediate next

NAE Draft response to client query. 1,050.00 0.3 315.00 NAE Attention to client query on 1,050.00 0.4 420.00 NAE Progress strategies in the UAE based on case

Luc Despins Invoice No. 471134 December 30, 2024 PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Rate Hours Amount

MVD Search for and compile 875.00 2.0 1,750.00

MVD Search for and compile 875.00 1.7 1,487.50

SB Attention to key case materials for case team review. 450.00 0.4 180.00

instructions Emily Beirne. 1,875.00 0.4 750.00

and draft response. 1,875.00 0.3 562.50 PRH Call team on next steps regarding strategy and client

ERB Consider strategy/client update and confer with team. 1,300.00 0.8 1,040.00 NAE Consider strategy and confer with Paul Hughes on 1,050.00 0.4 420.00 NAE Review note on 1,050.00 0.4 420.00 NAE Confer with team on strategies and consider Emily

NRS Confer with team regarding UAE strategy. 585.00 0.4 234.00 MVD Search for and compile 875.00 1.0 875.00 MVD Search for and compile 875.00 2.5 2,187.50

PRH Call with team regarding next steps and work product. 1,875.00 0.5 937.50 PRH Follow up call Nada Oteifi on UAE strategy. 1,875.00 0.5 937.50 PRH Review client email, liaise Emily Beirne regarding client call and review further communications. 1,875.00 0.3 562.50

Case 22-50073 Doc 3961 Filed 01/10/25 Entered 01/10/25 12:55:01 Page 10 of 12

LucDespins Invoice No. 471134 December 30, 2024 PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Hours Amount

ERB Confer with team; work on client update presentation 1,300.00 1.1 1,430.00 deck. ERB Conespondence with Luc Despins and Nick Bassett. 1,300.00 0.1 130.00 NAE Attention to exchange with client. 1,050.00 0.1 105.00 NAE �rlbtfal �JIBPJ&Kt[gfes�aft client presentation on 1,050.00 1.8 1,890.00 NAE Team call to discuss strategies in UAE and debrief with

NRS Prepare client slide deck; confer with Nada Oteifi on

NRS Confer with team regarding 585.00 0.6 351.00

PRH Liaise client regarding client meeting. 1,875.00 0.3 562.50 PRH Run through with team ahead of client call. 1,875.00 1.0 1,875.00 PRH Conference with team devising strategy and drafting

PRH Call Luc Despins and team regarding UAE strategy. 1,875.00 1.3 2,437.50 PRH Debrief after call and follow up actions. 1,875.00 0.5 937.50 PRH Final preparation for client call. 1,875.00 0.3 562.50 ERB Confer regarding client update presentation and input comments/changes. 1,300.00 0.9 1,170.00 NAE Revise and suggest edits to client deck. 1,050.00 0.5 525.00 NAE Draft action items following client call. 1,050.00 0.2 210.00 NAE Revise draft talking points for client call. 1,050.00 0.4 420.00 NAE Confer with team to progress client deck. 1,050.00 0.7 735.00 NAE Prep for and attend client call. 1,050.00 1.6 1,680.00 NAE Review internal note on 1,050.00 0.5 525.00

Case 22-50073 Doc 3961 Filed 01/10/25 Entered 01/10/25 12:55:01 Page 11 of 12

Luc Despins Invoice No. 471134 December 30, 2024 PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Rate Hours Amount

NAE Confer with team on UAE strategies and progress client presentation. 1,050.00 1.0 1,050.00 NRS Amend client slide deck; confer with team on the same. 585.00 5.0 2,925.00 NRS Confer with team in relation to upcoming client

NRS Attend call with client. 585.00 1.1 643.50

PRH Debrief following client call and plan next steps. 1,875.00 1.0 1,875.00 PRH Confer Nada Oteifi regarding 1,875.00 0.3 562.50 PRH Summary review of additional documents received from Paul Hastings team. 1,875.00 0.5 937.50 ERB Prepare for and attend update call with Luc Despins and wider team to set out preliminary strategy

ERB Work on preliminary strategy presentation, including 1,300.00 3.1 4,030.00 ERB Confer regarding client presentation presenting initial

ERB Review and comment upon draft slide deck for client update presentation. 1,300.00 0.3 390.00 ERB Correspondence with Luc Despins, Nick Bassett. 1,300.00 0.2 260.00 ERB Confer with case team next steps after client update presentation, discuss potential additional workstream

NAE Team worklist meeting to progress action items. 1,050.00 1.0 1,050.00 NRS Confer with team on upcoming action items. 585.00 1.0 585.00

PRH Conduct detailed review of documents received from client and confer team. 1,875.00 1.0 1,875.00

Luc Despins Invoice No. 471134 December 30, 2024 PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Rate Hours Amount

PRH Call Nada Oteifi and review and amend email to client regarding Kroll queries. 1,875.00 0.4 750.00

and revise email to client with queries. 1,050.00 0.4 420.00

for case team attention. 450.00 0.4 180.00

Total Current Fees & Disbursements \$93,478.19