Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #4053

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

| -----------------------------------------------------------<br>x | | | | | |------------------------------------------------------------------|-------------|-------------------------|--|--| | In re: | :<br>: | Chapter 11 | | | | HO WAN KWOK et al., | :<br>:<br>: | Case No. 22-50073 (JAM) | | | | Debtors.1 | :<br>: | Jointly Administered | | | | ----------------------------------------------------------- | x | | | |

# **CHAPTER 11 TRUSTEE'S MOTION, PURSUANT TO BANKRUPTCY RULE 9006(b), FOR ENTRY OF ORDER EXTENDING TIME FOR PROFESSIONALS TO FILE INTERIM FEE APPLICATIONS**

Luc A. Despins, in his capacity as the Chapter 11 Trustee (the "Trustee") appointed in the chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok (the "Debtor"), hereby respectfully moves (this "Motion"), pursuant to Federal Rule of Bankruptcy Procedure 9006(b), District of Connecticut Local Rule of Civil Procedure 7(b), and the Court's *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals* [ECF No. 2094] (the "Compensation Procedures Order"), for an extension of time of ten (10) days, from February 14, 2025, through and including February 24, 2025, for professionals (the "Professionals") employed pursuant to 11 U.S.C. §§ 327 or 1103 by the Trustee,

<span id="page-0-0"></span>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).

Genever Holdings Corporation and Genever Holdings LLC, or the Official Committee of Unsecured Creditors (the "Committee"), to file interim fee applications. [2](#page-1-0)

Cause exists for the Court to approve this extension. The Trustee's Professionals have been and remain engaged with respect to multiple tasks in and related to the Chapter 11 Case, including, among other things, an evidentiary hearing held earlier today, preparing to file dozens of new and amended avoidance complaints this week, and preparing a reply brief due February 15, 2025 in support of the Trustee's motion for summary judgment in *Despins v. Taurus Fund LLC*, et al. [Adv. Proc. No. 23-5017]. **The Trustee has confirmed that the Committee consents, and the Office of the United States Trustee does not oppose , the requested extension.**

*[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]*

<span id="page-1-0"></span>² Interim fee applications for Professionals that have requested compensation under the Compensation Procedures Order are due no later than 45 days after the conclusion of any Interim Fee Period (as defined in the order). The previous Interim Fee Period concluded on December 31, 2024; hence, absent extension, the deadline is presently February 14, 2025.

WHEREFORE, the Court should grant this Motion by entering the Proposed Order appended hereto and grant such other and further relief as is just and proper.

Dated: February 11, 2025 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

By: */s/ Patrick R. Linsey* 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

*and*

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

*and*

Douglass Barron (admitted *pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 douglassbarron@paulhastings.com

*Counsel for the Chapter 11 Trustee*

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

| --------------------------------------------------------------- | x | |-----------------------------------------------------------------------------|-----------------------------------| | In re: | :<br>:<br>Chapter 11 | | 1 | : | | HO WAN KWOK,<br>et al., | :<br>Case No. 22-50073 (JAM)<br>: | | Debtors.<br>--------------------------------------------------------------- | :<br>(Jointly Administered)<br>x |

# **[PROPOSED] ORDER EXTENDING TIME FOR PROFESSIONALS TO FILE INTERIM FEE APPLICATIONS**

Upon the motion (the "Motion")[2](#page-3-1) of 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") for entry of an order (this "Order") extending the time under the Compensation Procedures Order for Professionals to file interim fee applications (the "Fee Applications"); upon the consent of the Committee; without opposition by the Office of the United States Trustee; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED THAT:

- 1. The Motion is granted as set forth herein. - 2. The time by which the Professionals shall file their respective Fee Applications

pursuant to the Compensation Procedures Order is extended through and including February 24, 2025.

3. This Court retains exclusive jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order.

<span id="page-3-0"></span>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) 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).

<span id="page-3-1"></span>² Capitalized terms used but not otherwise defined herein have the meanings given to such terms in the Motion.

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

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK et al., | :<br>:<br>: | Case No. 22-50073 (JAM) | | Debtors. | :<br>: | Jointly Administered | | ----------------------------------------------------------- | x | |

#### **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on the date hereof, the foregoing Motion, and all declarations, exhibits and attachments thereto, was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case eligible to receive electronic service by operation of the Court's electronic filing ("CM/ECF") system.

Dated: February 11, 2025 New Haven, Connecticut

> By: */s/ Patrick R. Linsey* 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

> *Counsel for the Chapter 11 Trustee*