Guo Wengui / Miles Guo — bankruptcy case · NOTICE · ECF #3993

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

------------------------------------------------------- x **NOTICE OF FILING OF UPDATED EXHIBITS TO FIRST INTERIM FEE APPLICATION OF CHRYSSAFINIS & POLYVIOU LLC, AS CYPRIOT LAW COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM AUGUST 15, 2024 THROUGH DECEMBER 31, 2024**

PLEASE TAKE NOTICE that, on January 2, 2025, Chryssafinis & Polyviou LLC ("CP

Law"), as Cypriot counsel to Luc A. Despins, in his capacity as the chapter 11 trustee (the

"Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Debtor"), filed its First

Interim Application of Chryssafinis & Polyviou LLC, as Cypriot Law Counsel, for Compensation

*and Reimbursement of Expens*es for the Period from August 15, 2024 through December 31,

2024 (the "Application") . PLEASE TAKE FURTHER NOTICE that the United States Trustee raised certain

concerns with respect to the time and expense detail attached to the Application.

PLEASE TAKE FURTHER NOTICE that after discussions with the United States

Trustee, CP Law has agreed to revise it exhibits to the Application so as to provide additional

time and expense detail, as requested by the United States Trustee. The updated exhibits are

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 and the Genever Debtor 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).

attached hereto as Exhibit 1. For the avoidance of doubt, the total amount of fees and expenses requested to be allowed pursuant to the Application remains unchanged. CP Law understands that the exhibits attached hereto resolve the concerns raised by the United States Trustee.

Dated: January 22, 2025 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

Nicholas A. Bassett (admitted pro hac vice) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al.,1 :

Debtors. : :

The undersigned hereby certifies that on the date hereof, the foregoing Notice was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case by operation of the Court's electronic filing ("CM/ECF") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF system.

Dated: January 22, 2025 New York, New York

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

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).

15/08/2024  Review of the Complaint to be filed in the US a CY law perspective (GM 12 units). Handling emails with

16/08/2024  Handling emails with Luc Despins re

20/08/2024  Call with Barron Douglass (GM 12 units). Handling emails with Barron Douglass & Luc Despins (GM 3 units).  Call with Barron Douglass (CI 7.5 units). GM 15 units

21/08/2024  Call with Barron Douglass & Luc Despins (GM 10 units).  Call with Barron Douglass & Luc Despins (7.5 units). GM 10 units

22/08/2024  Review of documents sent by Barron Douglass in relation to proceedings taken against the Debtor in US/ London and BVI jurisdictions (45 units). GM 30 units

23/08/2024  Handling emails with Barron Douglass & Luc Despins (GM 2 units).  Drafting the Interim Application (CI 25 units). GM 2 units

27/08/2024  Internal liaising regarding the preparation of the Interim Application & relevant draft orders (GM 15 units and CI

28/08/2024  Review of documents & questions sent by Barron Douglass in relation to service of documents under the Hague Convention and related matters (GM 10 units). GM 10 units 30/08/2024  Drafting of the affidavit in support of the Interim Application (GM 25 units and CI 45 units).  Internal liaising re the Interim Application and related matters (GM5 units, CI 5 units, CH 5 units). GM 30 units

02/09/2024  Reaching out to numerous translators, coordinating with them, and ultimately engaging a licensed translator re the English / Greek versions to be filed in Court (CH 20 units).  Handling emails with Barron Douglass re the Interim Application & Affidavit (GM 4 units and CH 5 units). GM 4 units

03/09/2024  Review of Retention Application sent by Alex Bongartz

04/09/2024  Internal Liaising re the Retention Application (GM 5 units and CI 5 units).  Call with Alex Bongartz (GM 7.5 units) & Handling emails with Alex Bongartz and Luc Despins and providing relevant comments re the Retention Application and next steps to be followed (GM 5 units). GM 17.5 units

06/09/2024  Preparing covering letter re service upon Bouillor (GM

09/09/2024  Review of comments sent by Barron Douglass and incorporating the same in the affidavit (GM 10 units and CI 10 units).  Internal liaising & call with Client (GM 11 units and CI

10/09/2024  Handling emails with Barron Douglass (CI5 units)  Call with Barron Douglass re comments on the affidavit and exhibits to be attached (GM 10 units, CI 10 units

11/09/2024  Review of documents contained in the secure file sent by Sutton Ezra (GM 6 units, CI 10 units and CH 6 units) & Handling emails with Sutton Ezra (GM 2 units) GM 8 units

13/09/2024  Internal liaising (GM 5 units, CI 5 units and CH 5 units). GM 5 units

16/09/2024  Handling emails with Sutton Ezra re service of the US Action on Bouillor & requesting comments on Interim Application / Affidavit (GM 5 units).  Conducting search of records of Registrar of Companies re the Respondent entities (CI 5 units).  Arranging service of US Action upon Bouillor (GM 5 units).  Providing updated version of the Interim Application & Affidavit (CI 10 units).  Review of comments sent by Barron Douglass (CI 10

17/09/2024  Drafting 2nd affidavit on Urgency & Drafting of the Order Sought (GM 5 units and CI 25 units). GM 5 units

18/09/2024  Call with Barron Douglass in relation to the timing of the filing of the Retention Application, discussing comments on Interim Application and relevant affidavit (CI 5 units).  Handling emails with Barron Douglass requesting documents to be used as exhibits in the Interim Application/ Affidavit (CI 3 units).

Arranging the signing of the retainers (CI 2 units). CI 10 units 19/09/2024  Preparing Exhibits (CH 33 units)  Handling emails with Barron Douglass re final comments on Interim Application / Affidavit and on disclosure of confidential information (GM 5 units).  Call with Barron Douglass re final comments and filing of the Interim Application (GM 5 units).  Internal Liaising between re the above (CI 10 units and

20/09/2024  Effecting final comments on the Interim Application & Affidavit and filing the same on 20/09/2024 (GM 18 units and CI 10 units).  Handling emails with Barron Douglass re retainers, urgency affidavit, filling of the Interim Application and explaining the procedure of the Hearing on 25/09/2024

23/09/2024  Drafting of Written Address in view of the Hearing of the Interim Application on 25/09/2024 (CI 26 units).  Preparing for the Hearing (GM8 units).  Handling emails with Bongartz Alex re the Retention

24/09/2024  Handling emails with Luc Despins & Barron Douglass re Written Address in view of hearing on 25/09/2024

25/09/2024  Preparing for the Hearing of the Interim Application, which was rescheduled for 27/09/2024 (GM 20 units).  Drafting of the Undertaking (CH 8.5 units). GM 20 units

26/09/2024  Handling emails with Barron Douglass answering to questions posted on specific paragraphs of the Affidavit and the upcoming Court Hearing on 27/09/2024 (GM 2

27/09/2024  Travelling to Limassol, attending the Hearing of the Interim Application and addressing orally the Judge. Securing an Interim Order on an ex-parte basis (GM 34 units and CI 34 units).  Handling emails / updating Luc Despins et all re the same and answering to questions posted re the guarantee (GM 10 units).  Liaising with the Court's Registrar re the Drawn-up Orders / copies for the purposes of service (CI 10 units

30/09/2024  Handling emails with Barron Douglass, Alex Bongartz answering to questions posted re service of documents, transfer of funds for the purposes of the guarantee and related matters (GM 5 units).  Call with Luc Despins re service of the documents in London (GM 5 units).  Arranging service of the I.O and relevant docs upon Pafilia (CI 5 units and CH 5 units).  Drafting of the Application for leave to serve out of the Jurisdiction (GM 40 units and CI 25 units). GM 50 units

01/10/2024  Discussing with Client methods of service / postal and email addresses to be used in the prayer of the Application (GM 3 units).  Updating the Application based on Clients' latest comments (GM 17 units, CI 10 units and CH 13 units). GM 20 units

03/10/2024  Handling emails with Barron Douglass and Luc Despins re service on Mileson (GM 8 units).  Review of comments sent by Barron Douglass on the Application for leave to serve out of the Jurisdiction (CI

04/10/2024  Handling emails with Barron Douglass re the same & providing final / updated version of the said Application (CI 5 units).  Filling the said Application on 04/10/2024 (CH 6 units) CI 13 units

 Updating Barron Douglass et all re the same (CI4 units).

 Engaging an official translator (CH 7 units). 08/10/2024  Travelling to Limassol and attended the Hearing of our Application for leave to serve outside of the jurisdiction. The requested Orders were granted & updating the Client re the same (GM 30 units and CI 30 units).  Liaising with Pafilia's lawyer re the interim orders and GM 53 units

the letter to be sent to the LRO (GM18 units).  Drafting of Covering Letter to accompany the judicial documents to be served upon Qiang Guo (CI 9.5 units).  Handling emails with Barron Douglass & Luc Despins re the same (GM5 units). 09/10/2024  Handling emails with Barron Douglass et all updating the same re service of documents, letter to LRO etc

10/10/2024  Effecting service upon Qiang Guo both via email and DHL on 10/10/2024 (GM 5 units).  Handling emails with Barron Douglas et all updating the

 Handling emails with Barron Douglas et all re the service via DHL and related matters (GM5 units). 11/10/2024  Coordinating with GM & CI (GM 10.5, CI 10.5 and CH

16/10/2024  Handling emails with Luc Despins updating re the service upon Qiang Guo in London (GM5.5 units).  Drafting relevant affidavit of service to be filed in Court (GM 25 units and CI 27 units). GM 37.5 units

 Internal Liaising re filling of affidavit of service and related matters (GM 7 units, CI 7 units, CH 7 units). 17/10/2024  Liaising with Pafilia's lawyer re the comfort letter (GM 12 units).  Handling emails with Luc Despins et all updating the

21/10/2024  Travelling to Limassol where the I.O was fixed as returnable. The I.O was made absolute against all Respondents (GM 40 units and CI 40 units).  Handling emails with Luc Despins et all updating the GM 44 units

same (GM 4 units).  Calculating costs against Respondents 1 & 2 based on Court Scales (CI4 units). 24/10/2024  Handling emails with Barron Douglass & Luc Despins re the application for the return of the guarantee and Pafilia / LRO matter (GM 2 units). GM 2 units 19/11/2024  Handling emails with Luc Despins re awarded costs

26/11/2024  Drafting of Application for the return of the Guarantee (GM 40 and CI 20 units).  Liaising with Pafilia's lawyer re the same (GM 10 units). GM 52 units

 Handling emails with Luc Despins et all re the Application for the return of the Guarantee (GM2 units).

27/11/2024  Handling emails with Bongartz Alex re the Application for the return of the Guarantee (GM 1 unit). GM 1 unit 28/11/2024  Handling emails with Bongartz Alex et all re the email / comments received from Pafilia's lawyer re the Application for the return of the Guarantee / Answering to questions posted re the same (GM 3 units).  Internal Liaising between GM, CI, CH re the Application for the return of the Guarantee (GM 7 units, CI 7 units

02/12/2024  Liaising with Pafilia's lawyer on statements to be agreed and submitted to the Judge re the I.O and their costs (GM 2 units).  Handling emails with Luc Despins re the same (GM 3

03/12/2024  Handling emails with Luc Despins updating the same re discussion with Pafilia's lawyer on the matter of their costs & answering to questions posted re the same

 Drafting affidavit of service upon Bouillor re the Application for the cancelation of the Undertaking in

11/12/2024  Handling emails with Luc Despins re discussions with Pafilia's lawyer, statements to be presented before the Court and related matters (GM5 units).  Drafting minutes with statements to be presented before the Court on 16/12/2024 (GM 5 units).  Drafting of written address in support of the said Application and in view of the Hearing on 16/12/2024 (GM 7 units and CI 6 units).  Coordinating with GM re the above (CI5 units) 13/12/2024  Handling emails with Luc Despins in view of the newly appointed lawyer wishing to defend Bouillor and Kwok in the proceedings (GM 6 units).  Review of the opposition filed against our Application for cancellation of the Undertaking in damages (GM 8

17/12/2024  Preparing and sending letter to lawyer of Respondents 1 and 2. Coordinating with GM re the same (CI 7 units). CI 7 units 20/12/2024  Handling emails with Luc Despins re letter to be sent to the opposing counsel and related matters (GM5 units). GM 5 units 23/12/2024  Handling emails with Luc Despins re the revised letter and monies deposited in the Court's bank account (GM

CH (Chr. Hadjigeorgiou): 173 units/ 17 hours x EUR300 (EUR5.100) CI (Christos Ioannou): 576 units/57 hours x EUR375 (EUR21.375) GM (George Middleton): 706 units (6 minutes)/ 70 hours x EUR450 (EUR31.500)

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