Guo Wengui / Miles Guo — bankruptcy case · PETITION · ECF #4018

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re: :

HO WAN KWOK, et al., : :

Debtors.1 :

------------------------------------------------------ x COVERSHEET FOR THIRD INTERIM FEE APPLICATION OF PRAGER DREIFUSS AG

Interim Application of: Prager Dreifuss AG

Time Period: September 19, 2024 through December 31, 2024 Bankruptcy Petition Filed: February 15, 2022 Date of Entry of Retention Order: March 21, 2023 [Docket No. 3034] (effective as of January 17, 2024).

Fees: Expenses:

Voluntary Fee Reductions:

Fees Previously Requested: Requested Fees: Awarded Fees:

CHF 120,011.252 Retainer Request:

Expenses Previously Requested: Requested Expenses: Awarded Expenses:

CHF 2,400.20 Expense Detail: Retainer Received: Copies per page cost & total: Not applicable Not applicable

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 In addition, as detailed below, CHF 170,462.00 in fees and CHF 12,851.50 in expenses were previously paid in accordance with the Interim Compensation Order (as defined below) and Prager's monthly fee statements.

Monthly Total Fees Requested Fees Requested Fees Paid Expenses Paid 20% Fee

9/19/24 - CHF 94,301.25 CHF 75,441.00 CHF 10,431.00 CHF 75,441.00 CHF 10,431.00 CHF 18,860.25

11/1/24 - CHF 118,776.25 CHF 95,021.00 CHF 2,420.50 CHF 95,021.00 CHF 2,420.50 CHF 23,755.25

12/1/24 - CHF 64,842.50 CHF 51,874.00 CHF 1,296.85 -- -- CHF 12,968.50

TOTAL CHF 277,920.00 CHF 222,336.00 CHF 14,148.35 CHF 170,462.00 CHF 12,851.50 CHF 55,584.00

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

In re: :

HO WAN KWOK, et al., :

Debtors.1 :

THIRD INTERIM FEE APPLICATION OF PRAGER DREIFUSS AG, AS SWISS LAW COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM SEPTEMBER 19, 2024 THROUGH DECEMBER 31, 2024

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (such title, hereinafter, the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), Rule 2016-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Connecticut (the "Local Rules"), and the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals, dated August 18, 2023* [Docket No. 2094] (the "Interim Compensation Procedures Order"), Prager Dreifuss AG ("Prager" or the "Applicant"), as Swiss law counsel for 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"), hereby files this *Third Interim Application of Prager Dreifuss AG, as Swiss Law Counsel, for Compensation and Reimbursement of Expenses for the Period from September 19, 2024 through December 31, 2024*

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).

(the "Application"). By this Application, Prager requests interim allowance of professional fees incurred during the period from September 19, 2024 through and including December 31, 2024 (the "Application Period"). In support of this Application, Prager respectfully states as follows: JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

2. The legal predicates for the relief requested herein are sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.

3. Prager believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, and the *United States Trustee's Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases* (the "U.S. Trustee Guidelines").2 Prager respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 4. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains the Proposed Order granting this Application. - Exhibit B is a timekeeper summary that includes the name, hourly billing rate, aggregate hours, and amount of fees earned for each Prager individual who provided services during the Application Period; and - Exhibit C contains the detail of the fees and expenses incurred during the Application Period.

2 Prager reserves all rights as to the relevance and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation in these chapter 11 cases.

5. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed a voluntary petition for relief under the Bankruptcy Code in the United States Bankruptcy Court for the District of Connecticut (Bridgeport Division) (the "Court").

6. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Individual Debtor's chapter 11 case. No examiner has been appointed in the Individual Debtor's chapter 11 case.

7. On June 15, 2022, the Court entered a memorandum of decision and order [ECF No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the Individual Debtor's chapter 11 case.

8. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the Individual Debtor's chapter 11 case.

9. By order entered March 21, 2024, the Court authorized Prager's retention as Swiss law counsel to the Trustee [Docket No. 3034] (the "Retention Order") effective as of January 17, 2024 in the Debtor's chapter 11 case. The Retention Order authorizes Prager to be compensated on an hourly basis and reimbursed for actual and necessary out-of-pocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct. In accordance with the Retention Order, (a) Prager is authorized to charge a flat fee for disbursements in an amount equal to 2% of the total fees charged and (b) Prager is authorized to invoice its fees and expenses in Swiss Francs (CHF) and to have such fees and expenses paid in Swiss Francs (CHF), subject to the terms of the Interim Compensation Order.

10. On June 24, 2024, Prager filed its *First Interim Fee Application of Prager Dreifuss AG, as Swiss Law Counsel, for Compensation and Reimbursement of Expenses for Period from January 17, 2024 Through April 30, 2024* [Docket No. 3281] (the "First Interim Fee Application") requesting interim allowance of professional fees incurred during the period from January 17, 2024 through and including April 30, 2024. On July 23, 2024, the Court granted the First Interim Fee Application [Docket No. 3346].

11. On October 15, 2024, Prager filed its *Second Interim Fee Application of Prager Dreifuss AG, as Swiss Law Counsel, for Compensation and Reimbursement of Expenses for Period from May 1, 2024 Through September 30, 2024* [Docket No. 3698] (the "Second Interim Fee Application") requesting interim allowance of professional fees incurred during the period from May 1, 2024 through and including September 30, 2024. On November 13, 2024, the Court granted the Second Interim Fee Application [Docket No. 3812].

12. On August 18, 2023, the Court entered the Interim Compensation Procedures Order, which, among other things, approves procedures for the payment of 80% of fees and 100% of expenses on a monthly basis.

13. On November 4, 2024, Prager filed and served a monthly fee statement [Docket No. 3780] (the "October Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from September 19, 2024 through October 31, 2024, in the amounts of CHF 75,441.00 (80% of CHF 94,301.25) and CHF 10,431.00, respectively. No objections were filed in response to the October Fee Statement. Accordingly, the estate has paid Prager CHF 85,872.00 for fees and expenses with respect to the October Fee Statement.

14. On December 5, 2024, Prager filed and served a monthly fee statement [Docket No. 3863] (the "November Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from November 1, 2024 through November 30, 2024, in the amounts of CHF 95,021.00 (80% of CHF 118,776.25) and CHF 2,420.50, respectively. No objections were filed in response to the November Fee Statement. Accordingly, the estate has paid Prager CHF 97,441.50 for fees and expenses with respect to the November Fee Statement.

15. On January 22, 2025, Prager filed and served a monthly fee statement [Docket No. 3995] (the "December Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from December 1, 2024 through December 31, 2024, in the amounts of CHF 51,874.00 (80% of CHF 64,842.50) and CHF 1,296.85, respectively. The deadline to object to the December Fee Statement is February 12, 2025. Accordingly, at this time, the estate has not yet paid Prager for fees and expenses with respect to the December Fee Statement, but the Trustee intends to do so, in accordance with the Interim Compensation Procedures Order.

16. The Applicant is applying for compensation pursuant to Sections 330 and 331 of the Bankruptcy Code for legal services performed for the Trustee during the Application Period.

17. For the Application Period, the Applicant seeks allowance of CHF 277,920.00 as compensation for services rendered and allowance and reimbursement of CHF 14,148.35 in expenses incurred in connection with such services. The Applicant devoted 755.25 hours to this case during the Application Period, equating to an overall blended rate of CHF 367.98.

18. As noted, Prager has already received payment of CHF 170,462.00 of the fees incurred during the Application Period and CHF 12,851.50 of the expenses incurred during the Application Period, such that Prager is only seeking payment of (a) 80% of the fees and 100% of the expenses incurred on the December Fee Statement, i.e., CHF 53,170.85,3 and (b) the remaining 20% of its fees incurred during the Application Period, namely CHF 55,584.00.

19. Throughout the Application Period, the Applicant maintained records to indicate the name of each professional working on this matter, the time spent on a particular issue, and the nature of the work performed. These records, which describe in detail the services rendered by the Applicant, were created at the approximate time the services were performed.

20. Annexed hereto and made a part hereof as Exhibit C is a detailed billing report, upon which this application is based that contains each individual professional's time for the Debtor's bankruptcy case, itemizing the dates upon which services were rendered, including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the CHF value of such services. The time detail attached hereto as Exhibit C include certain redactions to protect against the disclosure of privileged or confidential information.

21. The Trustee retained Prager, effective as of January 17, 2024, principally to assist the Trustee in investigating and recovering property of the estate located in Switzerland. After

3 For the avoidance of doubt, the estate will pay this amount upon the expiration of the February 12, 2025 objection deadline with respect to the December Fee Statement, provided no objections are filed with respect to that fee statement, in accordance with the Interim Compensation Procedures Order.

the Debtor's chapter 11 case was recognized in Switzerland on July 24, 2024, Prager has continued to investigate estate assets that the Trustee has reason to believe are located in Switzerland, including by submitting information requests to numerous financial institutions in Switzerland and communicating with Swiss prosecutors. In addition, Prager has been conducting legal research and preparing related memoranda concerning, among other things, the recognition and enforcement of this Court's judgments in Switzerland.

22. The work undertaken by Prager to date has been significant, involving legal research and motion practice, factual analysis, correspondence, and strategic input. This work remains ongoing, with additional work expected in due course.

23. No prior application for the relief requested has been made. However, as noted, certain fees and expenses incurred during the Application Period were previously paid in accordance with the Interim Compensation Procedures Order.

24. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee in connection with the chapter 11 cases herein.

25. Applicant respectfully submits that its services have benefited the Debtor's estate with the expertise and skill required to, among other things, conduct an investigation into estate assets located in Switzerland and seek the recovery of such assets. The services for which such compensation is requested were performed for and on behalf of the Trustee. Such services have been necessary to protect and enforce the rights and interests of the Debtor's estate in connection with these chapter 11 cases. The reasonable value of services rendered by Prager in these cases is based upon Prager's usual hourly rates for matters of this nature.

26. Section 330 of the Bankruptcy Code prescribes the general standards for determining the amount of compensation to be paid to professionals. The Applicant submits that the amount sought for the Application Period represents reasonable compensation for professional services rendered based upon the time spent, the nature, the extent, and the value of such services, taking into account the cost of comparable services in a non-bankruptcy case.

27. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code provides that, after notice and a hearing, the Court may award a professional employed under 11 U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).4

28. In determining the amount of "reasonable compensation," the Court must consider the nature, extent, and value of the services, taking into account all the relevant factors, including the time spent on such services, the rates charged for such services, whether the services were necessary and beneficial, whether the services were performed in a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communication Systems, Inc., 395 B.R. 512 (D. Conn. 2008).

4 Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code "on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis." 11 U.S.C. § 328(a).

29. In assessing the "reasonableness" of the fees requested, the Second Circuit has stated that courts should consider the factors enumerated in Johnson v. Ga. Highway Express, Inc., 5 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections, 522 F.3d 182, 190 (2d Cir. 2007) (citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir.1974), abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87, 92–93, 96 (1989)). The "lodestar method" of calculating the reasonable fee contemplates "the number of hours reasonably expended . . . multiplied by a reasonable hourly rate." See Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); Gisbrecht v. Barnhart, 535 U.S. 789, 801 (2002); Perdue v. Kenny A., 130 S.Ct. 1662, 1672 (2010); In re Drexel Burnham Lambert Grp., Inc., 133 B.R. 13 (Bankr. S.D.N.Y. 1991). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544 F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.6 See In re Nine Assocs., Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine Magazine, Inc., 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); Green v. City of New York, 403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); see generally 3 COLLIER ON BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing First Colonial

5 The twelve Johnson factors are (1) the time and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service properly, (4) the preclusion of other employment by the attorney due to acceptance of the case, (5) the customary fee, (6) whether the fee is fixed or contingent, (7) the time limitations imposed by the client or the circumstances, (8) the amount involved and the results obtained, (9) the experience, reputation, and ability of the attorneys, (10) the "undesirability" of the case, (11) the nature and length of the professional relationship with the client, and (12) awards in similar cases. Johnson, 488 F.2d at 717-19.

6 The factors articulated in First Colonial were first articulated by the Fifth Circuit in Johnson, with the First Colonial court adding the factor of the "spirit of economy," which was later rejected by Congress. See Stroock & Stroock & Lavan v. Hillsborough Holdings Corp. (In re Hillsborough Holdings Corp.), 127 F.3d 1398, 1403 (11th Cir. 1997).

and Johnson as the "leading cases with regard to the factors to be considered in determining a reasonable allowance of compensation").

30. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Prager is fair and reasonable.

38. No agreement or understanding exists between Prager and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. Prager will not, in any form or guise, share or agree to share compensation for services with any person, nor will Prager share in the compensation for any other person rendering service in these cases, except as so provided by Section 504(b) of the Bankruptcy Code and Rule 2016 of the Bankruptcy Rules.

39. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or Prager has for any reason not sought compensation or reimbursement with respect to such services, Prager reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these chapter 11 cases. Also, Prager does not waive, and expressly reserves, its right to respond to any objections regarding this Application and the amounts sought for services rendered and expenses incurred. [Remainder of page intentionally left blank.]

WHEREFORE, Prager respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of CHF 277,920.00 and reimbursement of CHF 14,148.35 in expenses, (ii) authorizing and directing prompt payment of fees and expenses from the estate, to the extent not already paid, (iii) allowing such compensation and payment for professional services rendered without prejudice to Prager's right to seek further compensation and/or payment from the estates for the full value of services performed and expenses incurred, and (iv) granting Prager such other and further relief as is just.

Daniel Hayek PRAGER DREIFUSS AG Mühlebachstrasse 6 CH-8008 Zürich

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

The undersigned hereby certifies that on the date hereof, the *Third Interim Application of Prager Dreifuss AG, as Swiss Law Counsel, for Compensation and Reimbursement of Expenses for the Period from September 19, 2024 through December 31, 2024* (the "Application")2 was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 cases 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.3 In addition, to the extent not covered by the foregoing, copies of the Application were served on the twenty (20) largest creditors in the Debtor's chapter 11 case. Parties may access this filing through the Court's CM/ECF system.

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 used but not defined in this Certification shall have the meanings ascribed to them in the Application.

3 To the extent that the foregoing was filed outside regular business hours, service by mail on recipients unable or not qualified to accept electronic notice was made on the next business day.

New York, New York By: /s/ G. Alexander Bongartz

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

Case 22-50073 Doc 4018 Filed 01/30/25 Entered 01/30/25 15:07:10 Page 16 of 36

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

**[PROPOSED] ORDER GRANTING THIRD INTERIM FEE APPLICATION OF PRAGER DREIFUSS AG, AS SWISS LAW COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM SEPTEMBER 19, 2024 THROUGH DECEMBER 31, 2024**

Upon consideration of the Application (the "Application") of Prager Dreifuss AG

("Prager"), as Swiss law counsel for 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"),2 for interim

allowance of compensation and reimbursement of expenses from September 19, 2024 through

December 31, 2024; and sufficient notice having been given; and a hearing having been held on

\_\_\_\_\_\_\_\_, 2025 and due consideration having been given to any responses thereto; and sufficient

cause having been shown therefor, it is hereby:

1. ORDERED that the Application is granted, pursuant to 11 U.S.C. §§ 330 and 331,

and compensation in the amount of CHF 277,920.00 and reimbursement of expenses in the

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 adopt the definitions set forth in the Application.

amount of CHF 14,148.35 are awarded to Prager, subject to final adjustment and disgorgement in the event all administrative expenses are not paid in full; it is further

2. ORDERED that nothing herein modified the Retention Order; it is further

3. ORDERED that the estates are authorized and directed to pay Prager's fees in the amount of CHF 55,584.00, i.e., 20% of the fees allowed in paragraph 1 above, within fourteen days of the date of this Order; it is further

4. ORDERED that this Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order; it is further

5. ORDERED that the Trustee and Prager are authorized and empowered to take all necessary actions to implement the relief granted in this Order; it is further

6. ORDERED that notwithstanding the possible applicability of Bankruptcy Rules 6006(d), 7062, 9014, or otherwise, the terms and conditions of this Order shall be immediately effective and enforceable upon its entry; and it is further

7. ORDERED that all time periods set forth in this Order shall be calculated in accordance with Bankruptcy Rule 9006(a).

Case 22-50073 Doc 4018 Filed 01/30/25 Entered 01/30/25 15:07:10 Page 19 of 36

Sangiorgio, Shannon 200.45 175.00 35,078.75

Case 22-50073 Doc 4018 Filed 01/30/25 Entered 01/30/25 15:07:10 Page 20 of 36

Invoice period: September 19, 2024 – October 31, 2024

19.09.2024 rev. of file OJY 0.00% 1.20 25.09.2024 Emails to OJA with law review articles re same GJ 0.00% 0.20

01.10.2024 Meeting with MMA and OJY reg. Memo on SSA 0.00% 0.35 01.10.2024 Revision of memo on SSA 0.00% 0.10 01.10.2024 amend draft memo re MMA 0.00% 1.00 01.10.2024 conf. OJY re request letters MMA 0.00% 0.20 02.10.2024 Revision of memo on SSA 0.00% 3.15

02.10.2024 work on letter HA 0.00% 0.70

02.10.2024 rev. request for information MMA 0.00% 0.80 02.10.2024 conf HA/SSA re memo on MMA 0.00% 0.25

03.10.2024 Revision of memo on SSA 0.00% 5.60

03.10.2024 rev. letter to HA 0.00% 0.30 03.10.2024 Conf. OJY to give comments on letter HA 0.00% 0.30 03.10.2024 E-Mail to Luc and Alex re: letter HA 0.00% 0.50

Alex, first results data base HA 0.00% 0.70 03.10.2024 Review RFI input PH re OJY 0.00% 2.30 03.10.2024 review Swiss law regarding GJ 0.00% 1.00

03.10.2024 conf SSA regarding GJ 0.00% 0.50

03.10.2024 rev. emails on the draft request for information MMA 0.00% 0.20 04.10.2024 Assess Input re OJY 0.00% 2.40 04.10.2024 Draft RFI re OJY 0.00% 4.35 04.10.2024 amend memo on MMA 0.00% 1.30 04.10.2024 Call re Luc and Alex re next steps OJY 0.00% 0.80 04.10.2024 Instructing OJY 0.00% 1.00 04.10.2024 Conf. OJY re: draft letter to HA 0.00% 0.50 04.10.2024 Call Luc and Alex re: next steps, investigations in HA 0.00% 0.70

05.10.2024 E-Mail to Luc HA 0.00% 0.10

07.10.2024 Revision of memo on SSA 0.00% 5.55 07.10.2024 Finializing RFI OJY 0.00% 2.55

07.10.2024 rev. extract of HA 0.00% 0.30 07.10.2024 Conf. OYJ re: and e-mail to be drafted HA 0.00% 0.30 07.10.2024 Deal. w. motion to obtain Certificate of Finality (District

07.10.2024 Meeting with MMA reg. memo on SSA 0.00% 0.30 07.10.2024 conf HA/SSA re memo on MMA 0.00% 0.30 07.10.2024 conf OJY re request letter MMA 0.00% 0.30 07.10.2024 conf OJY re MMA 0.00% 0.20 08.10.2024 Revision of memo on SSA 0.00% 1.70

08.10.2024 rev. various and anwser e-mails of Alex HA 0.00% 0.50 08.10.2024 Conf. OJY re: Lettrs to HA 0.00% 0.50 08.10.2024 rev. and answer E-mail Alex on fees HA 0.00% 0.50 08.10.2024 rev. memo on MMA 0.00% 0.80

09.10.2024 rev.

09.10.2024 rev. drafts requests for information MMA 0.00% 0.40 09.10.2024 amend memo on MMA 0.00% 0.80 10.10.2024 Revision of Memo SSA 0.00% 6.85 10.10.2024 Finalising Drafts and Annexes OJY 0.00% 1.55

10.10.2024 conf SSA re memo on MMA 0.00% 0.70

14.10.2024 Meeting with OJY reg. Memo on SSA 0.00% 0.80 14.10.2024 Conf re Memo OJY 0.00% 0.55 14.10.2024 Editing down of the memo reg. SSA 0.00% 1.70 14.10.2024 Letter re RFIs OJY 0.00% 1.95

15.10.2024 Revision of memo on SSA 0.00% 0.55 16.10.2024 Memo finalisation OJY 0.00% 0.70

16.10.2024 Conf. Olli and Marc: re: Call HA 0.00% 0.30 16.10.2024 E-Mail to Luc Despins HA 0.00% 0.30 16.10.2024 rev. memo on HA 0.00% 0.90 16.10.2024 Research reg. SSA 0.00% 2.10

17.10.2024 legal research and conf OJY re GJ 0.00% 1.50

18.10.2024 Draft next RFIs OJY 0.00% 6.95

re document request, conf OJY MMA 0.00% 0.25 20.10.2024 General Questions from Trustee OJY 0.00% 5.60 21.10.2024 Review of comments and questions reg. memo on SSA 0.00% 0.75 21.10.2024 General Questions from Trustee OJY 0.00% 7.35 21.10.2024 Meeting with OJY reg. revision of memo SSA 0.00% 0.80 21.10.2024 Revision of memo reg. SSA 0.00% 4.25 21.10.2024 rev. and discuss draft answers to Alex HA 0.00% 0.50 21.10.2024 Call w, Luc and Alex re: HA 0.00% 1.00 21.10.2024 Meeting with HA and OJY reg. Memo on SSA 0.00% 0.60 21.10.2024 Update Call OJY 0.00% 1.10 21.10.2024 Call with HA, OJY, Luc Despins and Alex Bongartz SSA 0.00% 1.00 21.10.2024 conf OJY re questions trustee on

22.10.2024 Draft re longer Memo OJY 0.00% 2.85

22.10.2024 rev. content of stick, Conf. OJY HA 0.00% 0.70 23.10.2024 Draft re Memo OJY 0.00% 5.40 23.10.2024 Revision of memo SSA 0.00% 0.50

23.10.2024 Creating an overview of SSA 0.00% 0.50

23.10.2024 conf OJY re MMA 0.00% 0.20

24.10.2024 Creating an overview of SSA 0.00% 7.55

24.10.2024 Update Call OJY 0.00% 0.40 24.10.2024 rev. email Alex re MMA 0.00% 0.30 24.10.2024 conf HA/OJA re status and next steps MMA 0.00% 0.30 24.10.2024 call Paul Hastings re status and next steps MMA 0.00% 0.50 24.10.2024 rev. documents provided by MMA 0.00% 0.50

25.10.2024 Creating an overview of SSA 0.00% 8.30 25.10.2024 Memo including new documents OJY 0.00% 6.90 25.10.2024 legal research and study of GJ 0.00% 2.50

26.10.2024 E-Mails Luc about HA 0.00% 0.50

28.10.2024 conf HA/OJY re MMA 0.00% 0.20 28.10.2024 Conf OJY rev. e-mail HA 0.00% 0.50 28.10.2024 conf with OJY regarding GJ 0.00% 0.50

28.10.2024 Draft Reminder to OJY 0.00% 0.75 28.10.2024 rev. docs, call HA 0.00% 0.50 28.10.2024 emails Alex Bongartz re MMA 0.00% 0.30

29.10.2024 Update re Workstreams OJY 0.00% 1.10

29.10.2024 Conf OYA re update email to client MMA 0.00% 0.50 29.10.2024 Conf. OJY re: Update etc. HA 0.00% 0.50

31.10.2024 rev. additional request letter MMA 0.00% 0.60

31.10.2024 call criminal prosecution re MMA 0.00% 0.20 31.10.2024 re additional Questions OJY 0.00% 2.40 31.10.2024 Federal Prosecution OJY 0.00% 0.30

31.10.2024 Creating an overview of SSA 0.00% 4.10 30.10.2024 rev.

30.10.2024 conf OJY re comments client on

30.10.2024 rev. memo on MMA 0.00% 1.00 30.10.2024 RFI feedback OJY 0.00% 2.05 30.10.2024 rev.

30.10.2024 Proof reading of memo reg. SSA 0.00% 0.70

30.10.2024 Creating an overview of SSA 0.00% 7.50 29.10.2024 review memo on GJ 0.00% 0.70 29.10.2024 email to client re MMA 0.00% 1.00 29.10.2024 emails to client re MMA 0.00% 1.00 29.10.2024 E-Mails Luc and Alex HA 0.00% 0.20

01.11.2024 Disbursements 0.00% 1'886.00

Sangiorgio, Shannon 71.20 175.00 12'460.00

Invoice period: November 1, 2024 – November 30, 2024

01.11.2024 Draft: 2nd. RFI to OJY 0.00% 0.60 01.11.2024 Draft: RFI to OJY 0.00% 3.95 01.11.2024 Draft: Additional questions OJY 0.00% 2.25 01.11.2024 Draft: Letter OJY 0.00% 0.65 01.11.2024 Conf. OJY re: different requests to

01.11.2024 rev. letter MMA 0.00% 0.20 01.11.2024 rev. e-mails Luc HA 0.00% 0.20

01.11.2024 rev. draft additional letter to MMA 0.00% 0.20 01.11.2024 rev. draft information request MMA 0.00% 0.30

04.11.2024 Draft:

04.11.2024 rev. and comment Lt. HA 0.00% 0.40 04.11.2024 rev. and comment Lt. to HA 0.00% 0.70

04.11.2024 conf HA/OJY re MMA 0.00% 0.30

04.11.2024 conf OJY re status of workstreams MMA 0.00% 0.10 04.11.2024 Draft:

05.11.2024 Draft:

05.11.2024 Draft: legal basis OJY 0.00% 2.80

05.11.2024 Email: re second RFI and Update OJY 0.00% 0.35 05.11.2024 Research: re OJY 0.00% 2.45

06.11.2024 amend draft letter to MMA 0.00% 0.40

06.11.2024 call Alex re letter to MMA 0.00% 0.20 06.11.2024 conf OJY re letter to MMA 0.00% 0.10

07.11.2024 Draft: additional letter to OJY 0.00% 3.35 07.11.2024 Draft: Memo follow-up questions OJY 0.00% 2.20 07.11.2024 rev. letter to MMA 0.00% 0.50 07.11.2024 Call: with Alex OJY 0.00% 0.25

08.11.2024 Draft: Memo Follow-up questions OJY 0.00% 5.75 09.11.2024 Draft : Memo re additional questions OJY 0.00% 6.10 09.11.2024 review email OJY GJ 0.00% 0.50 09.11.2024 legal research regarding GJ 0.00% 1.80 09.11.2024 email to OJY GJ 0.00% 0.20 11.11.2024 Research reg. SSA 0.00% 4.80 11.11.2024 Drafte Memo re follow up OJY 0.00% 4.55

re additional information request MMA 0.00% 0.25 11.11.2024 Conf. OJY re: memo and return from

12.11.2024 Research reg. SSA 0.00% 2.60

12.11.2024 rev. draft information request to MMA 0.00% 0.40 12.11.2024 Meeting with HA and OJY reg. SSA 0.00% 1.00 12.11.2024 Revision of RFI to SSA 0.00% 1.15 12.11.2024 Draft: RFI to OJY 0.00% 3.20 12.11.2024 rev. additional information MMA 0.00% 0.40 12.11.2024 Emails: to PH OJY 0.00% 0.50

12.11.2024 Call Luc Despins HA 0.00% 0.50 12.11.2024 rev. draf letter to HA 0.00% 1.00 12.11.2024 conf HA/LCH/OYA/SSA re MMA 0.00% 0.50 12.11.2024 Call with HA, GJ, MMA and OJY reg. SSA 0.00% 0.50 12.11.2024 Call with HA, MMA, OJY and SSA re GJ 0.00% 0.50 13.11.2024 rev. information request to MMA 0.00% 0.40 13.11.2024 Research reg. SSA 0.00% 7.20 13.11.2024 Draft RFI re OJY 0.00% 2.85 13.11.2024 Reserach re OJY 0.00% 1.35 13.11.2024 Call with OJY reg. SSA 0.00% 0.45

13.11.2024 Doc. Review re OJY 0.00% 0.70

13.11.2024 Draft 3rd RFI to OJY 0.00% 2.40 13.11.2024 conf OJA re additional request MMA 0.00% 0.10 13.11.2024 conf OJA re status MMA 0.00% 0.10 13.11.2024 rev. final letter to MMA 0.00% 0.40 13.11.2024 rev. Letter to HA 0.00% 0.50 13.11.2024 rev. E-Mails Oli re HA 0.00% 0.20 14.11.2024 Research reg. SSA 0.00% 8.40 14.11.2024 Review: Documents OJY 0.00% 1.25 14.11.2024 Draft: 3rd RFI to OJY 0.00% 1.95

14.11.2024 rev.

14.11.2024 conf OJA re status MMA 0.00% 0.10 14.11.2024 conf OJA re status MMA 0.00% 0.10 15.11.2024 Research reg. SSA 0.00% 10.15 15.11.2024 Draft: Letter OJY 0.00% 1.45 15.11.2024 Draft: Letter OJY 0.00% 5.50 15.11.2024 rev. final letter to MMA 0.00% 0.10 15.11.2024 rev. final letter to MMA 0.00% 0.10 15.11.2024 email Alex re follow-up to MMA 0.00% 0.10 15.11.2024 conf HA/GJ/OJA re MMA 0.00% 0.40 15.11.2024 legal research regarding GJ 0.00% 4.00

15.11.2024 Research reg. SSA 0.00% 0.15 15.11.2024 Review Documents OJY 0.00% 1.55 15.11.2024 rev. follow-up request MMA 0.00% 0.30 15.11.2024 rev. memo re MMA 0.00% 0.70 15.11.2024 conf OJA/SSA re MMA 0.00% 0.25

15.11.2024 call HA, MME and OJY GJ 0.00% 0.40 15.11.2024 email to Luc Despins GJ 0.00% 0.20

18.11.2024 Discussion re OJY 0.00% 2.35

18.11.2024 Research re OJY 0.00% 5.40 18.11.2024 rev. final version follow-up letter MMA 0.00% 0.25 18.11.2024 Draft: Letter to OJY 0.00% 0.70 18.11.2024 Conf. GJ and Team re: HA 0.00% 1.70

19.11.2024 Research reg. SSA 0.00% 3.55 19.11.2024 Research: re OJY 0.00% 7.65 19.11.2024 Draft: letter to OJY 0.00% 1.40 19.11.2024 rev. letter MMA 0.00% 0.20 19.11.2024 ref. draft follow-up MMA 0.00% 0.25 19.11.2024 call Alex Bongartz re MMA 0.00% 0.20 19.11.2024 Revision of memo on SSA 0.00% 5.00 20.11.2024 Revision of memo on SSA 0.00% 4.50 20.11.2024 Draft: Memo re OJY 0.00% 6.20 20.11.2024 Draft: Additional RFI re OJY 0.00% 1.45

20.11.2024 rev. letter MMA 0.00% 0.20

20.11.2024 Draft Letter re OJY 0.00% 1.35 20.11.2024 rev. follow-up MMA 0.00% 0.50 20.11.2024 email Alex re MMA 0.00% 0.25 20.11.2024 rev. draft response letter MMA 0.00% 0.20

20.11.2024 rev. emails Alex re response letters MMA 0.00% 0.20

letters inc. translation OJY 0.00% 7.00 21.11.2024 conf OJY re status information requests MMA 0.00% 0.30 21.11.2024 conf OJY re MMA 0.00% 0.20 21.11.2024 email Alex re MMA 0.00% 0.10 21.11.2024 email Alex re MMA 0.00% 0.10

22.11.2024 conf HA/OJY re status of MMA 0.00% 0.30

22.11.2024 rev. response letter MMA 0.00% 0.20 25.11.2024 Revision of memo on SSA 0.00% 7.40

25.11.2024 Response from OJY 0.00% 0.10 25.11.2024 Research and Draft OJY 0.00% 4.00 25.11.2024 rev. letter by attorney retained by MMA 0.00% 0.20

25.11.2024 rev. final information request to MMA 0.00% 0.20

25.11.2024 rev. additional documents provided by MMA 0.00% 0.20 25.11.2024 rev. amended information request to MMA 0.00% 0.30

25.11.2024 email Luc and Alex re new information obtained MMA 0.00% 0.20 25.11.2024 call with OJA regarding GJ 0.00% 0.50 25.11.2024 rev.

25.11.2024 Conf. OJY re: change letter HA 0.00% 0.30 25.11.2024 E-Mail Alex re. change letter HA 0.00% 0.50 26.11.2024 Revision of memo on SSA 0.00% 8.70 26.11.2024 Draft: Finalized letter to OJY 0.00% 1.00

26.11.2024 rev. and sign letter HA 0.00% 0.50 26.11.2024 rev. final version information request to MMA 0.00% 0.30 26.11.2024 rev. draft memo HA 0.00% 0.90 26.11.2024 Draft: Letter to OJY 0.00% 1.00 26.11.2024 conf OJY re letter to GJ 0.00% 0.10 26.11.2024 conf OJY re addition letter to MMA 0.00% 0.10 26.11.2024 review memorandum regarding GJ 0.00% 1.90 26.11.2024 legal research re GJ 0.00% 2.00 27.11.2024 Revision of memo on SSA 0.00% 8.85 27.11.2024 Draft: Letter to OJY 0.00% 0.30

27.11.2024 rev. letter MMA 0.00% 0.10 27.11.2024 conf HA/OJY re letter MMA 0.00% 0.20 27.11.2024 rev. letter. conf. OJY HA 0.00% 0.50

27.11.2024 E-Mail to Luc HA 0.00% 0.50 27.11.2024 review draft GJ 0.00% 1.00 27.11.2024 legal research re GJ 0.00% 1.00 27.11.2024 mark-up draft GJ 0.00% 1.00 27.11.2024 various conf with OJY GJ 0.00% 0.50 28.11.2024 Revision of memo on SSA 0.00% 7.50

28.11.2024 telephone with OJY regarding GJ 0.00% 0.50 28.11.2024 rev. follow-up letter MMA 0.00% 0.30 29.11.2024 Revision of memo on SSA 0.00% 8.25

03.12.2024 Disbursements 0.00% 2'375.50

Provider Hours Rate CHF Amount CHF Hayek, Daniel 13.70 750.00 10'275.00 Jany, Oliver 174.85 375.00 65'568.75 Jegher, Gion 25.50 650.00 16'575.00 Meili, Mark 16.90 550.00 9'295.00 Sangiorgio, Shannon 97.50 175.00 17'062.50

Invoice period: December 1, 2024 – December 31, 2024

01.12.2024 work on draft GJ 0.00% 6.00 02.12.2024 Letter from OJY 0.00% 0.20

02.12.2024 rev. letter MMA 0.00% 0.20 02.12.2024 conf HA/GJ/OJY re MMA 0.00% 0.30 02.12.2024 Reading of the SSA 0.00% 0.95 02.12.2024 Research re OJY 0.00% 1.10

03.12.2024 E-Mail Luc and Alex HA 0.00% 0.30 03.12.2024 Research re OJY 0.00% 1.10 03.12.2024 review and revise draft email to Luc Despin regarding

04.12.2024 Preparation re Call OJY 0.00% 2.10

and answer of Luc Despin; internal conference regarding options; call with PD team and Luc and Alex re options GJ 0.00% 2.00 04.12.2024 conf OJY re answer MMA 0.00% 0.20 04.12.2024 email Luc and Alex re answer MMA 0.00% 0.10

04.12.2024 Call with OJY reg. memo on SSA 0.00% 0.25 04.12.2024 Revision of memo reg. SSA 0.00% 2.50 04.12.2024 Call re next steps OJY 0.00% 0.80 04.12.2024 Call with HA, OJY and Luc reg. assets SSA 0.00% 1.05

04.12.2024 conf HA/GJ/OJY re strategy and next steps MMA 0.00% 0.50 04.12.2024 Call Luc and Alex re strategy Switzerland MMA 0.00% 0.80 04.12.2024 prep. call reading and with team HA 0.00% 1.00 04.12.2024 Call team Luc and Alex: discuss HA 0.00% 1.00 05.12.2024 Revision of memo reg. SSA 0.00% 2.95

05.12.2024 Research reg. SSA 0.00% 2.70

05.12.2024 Call with Alex Bongrartz OJY 0.00% 0.60 05.12.2024 Reserach: re OJY 0.00% 2.35 05.12.2024 Call with OJY and Alex reg. SSA 0.00% 0.60 05.12.2024 rev. memo re MMA 0.00% 0.70 05.12.2024 rev. memo etc. HA 0.00% 1.30 05 12 2024 conf OJY regarding GJ 0.00% 0.50 06.12.2024 Revision of memo reg. SSA 0.00% 4.00

06.12.2024 Research reg. SSA 0.00% 3.00 06.12.2024 Research re OJY 0.00% 2.20 06.12.2024 Call with Alex Bongartz OJY 0.00% 0.60

09.12.2024 conf HA/GJ/OJY re MMA 0.00% 0.50 09.12.2024 review and comment draft email of OJY re

10.12.2024 Research re OJY 0.00% 4.85 10.12.2024 Revision of memo reg. SSA 0.00% 4.40

10.12.2024 conf OJY re MMA 0.00% 0.20 10.12.2024 rev. options andreview of law HA 0.00% 1.00 10.12.2024 E-Mail to Luc and Alex HA 0.00% 0.50 11.12.2024 Revision of memo reg. SSA 0.00% 1.25

12.12.2024 Revision of memo on SSA 0.00% 0.30 12.12.2024 Draft: alternative Option OJY 0.00% 5.80 12.12.2024 Discussion: re legal options OJY 0.00% 0.50 13.12.2024 Draft: Letter to OJY 0.00% 3.20

13.12.2024 Call with HA, MMA, OJY, Luc and Alex SSA 0.00% 0.30 13.12.2024 Meeting with HA, MMA and OJY reg. call with Luc and

13.12.2024 Discussion re call OJY 0.00% 0.50

10. 12.2024 Call. Te flext Steps UJI U.UU 70 0.40

13.12.2024 perpare call with team HA 0.00% 0.50 13.12.2024 Call Luc / Alex HA 0.00% 0.90 13.12.2024 Meeting with HA, MMA, OJY and SSA reg. call with Luc

13.12.2024 Call with HA, MMA, OJY, SSA, Luc and Alex GJ 0.00% 0.30 13.12.2024 conf HA/GJ/OJY re strategy and legal options Switzerland MMA 0.00% 0.50 13.12.2024 call Luc/Alex re next steps MMA 0.00% 0.50 16.12.2024 Research: re OJY 0.00% 0.35

16.12.2024 Draft: Email re Comments OJY 0.00% 1.90

16.12.2024 rev. comments Alex on MMA 0.00% 0.50 17.12.2024 Research reg. SSA 0.00% 6.45 17.12.2024 Review: Transfers from Kwok OJY 0.00% 0.90 17.12.2024 Draft: Answers re Email OJY 0.00% 2.50 17.12.2024 Call with OJY reg. SSA 0.00% 0.55 17.12.2024 rev. letter MMA 0.00% 0.20 17.12.2024 draft email Alex re MMA 0.00% 0.40 17.12.2024 draft email Alex re MMA 0.00% 0.30 17.12.2024 Call: re Email OJY 0.00% 0.30 18.12.2024 Draft: Letter to OJY 0.00% 3.50

19.12.2024 Draft: English Mashine Translation OJY 0.00% 0.90 19.12.2024 Draft: Draft Letter for OJY 0.00% 4.90 20.12.2024 Draft: Fınalızıng Submission OJY 0.00% 3.20

20 12 2024 Review: Documents OJY 0.00% 1.30 20.12.2024 conf. HA/OJY re MMA 0.00% 0.40

08.01.2025 Disbursements 0.00% 1 296.85

Sangiorgio, Shannon 31.75 175.00 5'556.25