Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #4134

METADATA

Defendant
Guo Wengui / Miles Guo / Ho Wan Kwok
Court
CTB
Case No.
22-50073
ECF #
4134
Type
ORDER
Filed
2023-08-18

Monthly Fee Statement — In re Ho Wan Kwok (Miles Guo / Guo Wengui), CTB 22-50073 ECF #4134 (filed Aug 18, 2023). Forensic investigator Kroll, LLC, retained by Chapter 11 Trustee Luc A. Despins, requests interim payment of 80% of professional fees ($80,421.96) and 100% of expenses ($2,446.20) for asset recovery and investigation services rendered from January 1 through January 31, 2025.

FULL TEXT

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UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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x
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In re: : :

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Chapter 11
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HO WAN KWOK, et al., :

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Case No. 22-50073 (JAM)
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Debtors.1 : :

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Jointly Administered
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-------------------------------------------------------------- x MONTHLY FEE STATEMENT OF KROLL, LLC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JANUARY 1, 2025 THROUGH JANUARY 31, 2025

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In accordance with the Order Establishing Procedures for Interim Compensation and

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Reimbursement of Expenses for Retained Professionals, dated August 18, 2023 [Docket No.

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2094] (the "Interim Compensation Order"),2 Kroll, LLC ("Kroll") hereby submits this monthly statement (the "Monthly Fee Statement") seeking compensation for services rendered and reimbursement of expenses incurred as forensic investigators 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 January 1, 2025 through and including January 31, 2025 (the "Fee Period"). By this Monthly Fee Statement, Kroll respectfully requests payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the Fee Period, in the amounts of \$80,421.96 and \$2,446.20, respectively.

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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).

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2 Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Interim Compensation Order.

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SERVICES RENDERED AND EXPENSES INCURRED
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1. Attached hereto as Exhibit A is a timekeeper summary that includes the name, title, service line, standard rate, discounted rate, total hours, and total fees earned for each Kroll individual who provided services during the Fee Period. The rates charged by Kroll for services rendered to the Trustee are discounted per the engagement letter to the rates that Kroll charges generally for professional services rendered to its non-bankruptcy clients.

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2. Attached hereto as Exhibit B is a summary of Kroll's services rendered and compensation sought for the Fee Period organized by Project Category.

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3. Attached hereto as Exhibit C is a summary of Kroll's services rendered and compensation sought for the Fee Period organized by Matter ID.

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4. Attached hereto as Exhibit D is a summary of Kroll's expenses incurred and reimbursement sought for the Fee Period organized by Expense Type.

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5. Attached hereto as Exhibit E are Kroll's fee statements for services provided during the Fee Period.

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NOTICE AND OBJECTION PROCEDURES
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6. 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

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(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").

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7. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Kroll (Attn: Allen Pfeiffer (allen.pfeiffer@kroll.com) and (ii) the Notice Parties by email no later than March 13, 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.

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

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9. 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.

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Dated: February 20, 2025
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By:/s/ Allen Pfeiffer Allen Pfeiffer KROLL, LLC 55 East 52nd Street, Floor 17 New York, New York 10055 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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x
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In re: : :

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Chapter 11
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HO WAN KWOK, et al.,3 : :

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Case No. 22-50073 (JAM)
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Debtors. :

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(Jointly Administered)
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CERTIFICATE OF SERVICE
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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 Parties. Parties may access this filing through the Court's CM/ECF system.

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Dated: February 20, 2025 By: /s/ G. Alexander Bongartz

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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

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Counsel for the Chapter 11 Trustee
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3 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).

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EXHIBIT A HOURS AND RATES PER PROFESSIONAL
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Time Period: January 1-31, 2025.

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Timekeeper Title Service Line Standard Discounted Total Total Fees

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Rate Rate Hours
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Parizek, Pam Managing Director Forensic Investigations \$ 890 \$ 712 28.5 \$ 20,292.00

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and Intelligence
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Barker, James Associate Managing Forensic Investigations \$ 710 \$ 639 3.0 \$ 1,917.00

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Director and Intelligence
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Jones, Iain Associate Managing Forensic Investigations \$ 710 \$ 639 2.0 \$ 1,278.00

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Director and Intelligence
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Lazarus, Jordan Senior Manager Forensic Investigations \$ 575 \$ 518 12.4 \$ 6,417.00

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and Intelligence
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Lomas, Adam Senior Manager Forensic Investigations \$ 575 \$ 518 121.6 \$ 62,928.00

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and Intelligence
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Spier, Tre Research Analyst Forensic Investigations \$ 245 \$ 221 34.9 \$ 7,695.45

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and Intelligence 202.4 Total Hours and Fees: \$ 100,527.45
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Blended Hourly Rate:

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\$ 496.68 EXHIBIT B
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SUMMARY OF COMPENSATION BY PROJECT CATEGORY

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Time Period: January 1-31, 2025.

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U.S. Trustee Task Code and Project Category Hours Billed Fees Billed

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B110 Case Administration - \$ - B113 Pleadings Review - \$ -
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B120 Asset Analysis and Recovery 185.6 \$ 91,187.05

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B155 Court Hearings - \$ -
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B160 Fee/Employment Applications 5.0 \$ 2,626.40 B170 Fee/Employment Objections - \$ - B180 Avoidance Action Analysis - \$ - B181 Preference Analysis and Recovery Actions - \$ - B182 Post-Petition Transfers and Recovery Actions - \$ - Other Contested Matters (excl. B190 assumption/rejections motions) - \$ -

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B191 General Litigation - \$ - B192 Lender Litigation - \$ - B195 Non-Working Travel - \$ - B261 Investigations 11.8 \$ 6,714.00 TOTAL \$ 100,527.45 EXHIBIT C SUMMARY OF COMPENSATION BY MATTER ID
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Time Period: January 1-31, 2025.

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Hours
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Matter ID and Name Billed Fees Billed
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00001 General Debtor Representation 5.0 \$ 2,626.40 00002 Asset Recovery Investigation and Litigation 195.4 \$ 96,623.05 00003 HK USA Adversary Proceeding - \$ - 00004 Bravo Luck Adversary Proceeding - \$ - 00005 PAX Adversary Proceeding - \$ - 00006 SN Apartment Adversary Proceeding - \$ - 00007 Greenwich Land Adversary Proceeding - \$ - 00008 AIG Adversary Proceeding - \$ - 00009 Mei Guo Adversary Proceeding - \$ - 00010 Interpleader Adversary Proceeding - \$ - 00011 HCHK Adversary Proceeding - \$ - 00012 Golden Spring Adversary Proceeding - \$ - 00013 Mahwah Adversary Proceeding - \$ -

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00014 RICO Litigation - \$ -
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00015 Lamp Capital Adversary Proceeding - \$ - 00016 G-Club Adversary Proceeding - \$ - 00017 Rule of Law Adversary Proceeding - \$ - 00018 UAE Asset Recovery Actions 2.0 \$ 1,278.00 00019 Leading Shine Adversary Proceeding - \$ -

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00020 Gettr USA Proceeding - \$ - 202.4 \$ 100,527.45 EXHIBIT D SUMMARY OF ACTUAL AND NECESSARY EXPENSES
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Time Period: January 1-31,
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2025.

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Expense Category Matter ID Task Code Expense Amount

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Database and Research Fees for
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January Asset Recovery Investigation and Litigation Asset Analysis and Recovery \$

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438.60
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Valid8 Charges General Debtor Representation Case Administration 2,007.60

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TOTAL \$ 2,446.20 EXHIBIT E FEE DETAIL
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Timekeeper Date Matter Task Narrative Hours Amount

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Lomas, Adam 1/1/2025 Asset Recovery Asset Analysis Attention to analysis of postpetition 8.4 \$ 4,347.00 Investigation and and Recovery inflows and funds seized by

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Litigation related email to P. Parizek and J. Lazarus re: discussion of working
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analysis. Parizek, Pam 1/2/2025 Asset Recovery Asset Analysis Review A. Lomas analysis re: forfeiture 2.3 \$ 1,637.60 Investigation and and Recovery amounts and Litigation account balances (.3), call with A. Lomas, J. Lazarus re: same (.8), report to Paul Hastings (L. Despins, N. Bassett, D. Barron) re: same (.8), call with A. Lomas re: methodology (.4). Lomas, Adam 1/2/2025 Asset Recovery Asset Analysis Prepare schedule analysis of postpetition 3.7 \$ 1,914.75 Investigation and and Recovery activity in

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Litigation subject to
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Lomas, Adam 1/2/2025 Asset Recovery Asset Analysis Meeting re: analysis of

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and 0.8 \$ 414.00
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Investigation and and Recovery other investigative updates, with Paul Litigation Hastings [L. Despins and D. Barron] and P. Parizek. Lomas, Adam 1/2/2025 Asset Recovery Asset Analysis Meeting with P. Parizek and J. Lazarus 0.9 \$ 465.75 Investigation and and Recovery re: working analysis.

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Litigation
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Lazarus, Jordan 1/2/2025 Asset Recovery Asset Analysis Phone call with A. Lomas and P. Parizek 0.8 \$ 414.00 Investigation and and Recovery re: analysis schedules for

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discussion
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Litigation and related matters. Lomas, Adam 1/3/2025 Asset Recovery Asset Analysis Continued attention to schedule analysis 2.8 \$ 1,449.00 Investigation and and Recovery of postpetition activity in

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Litigation subject to
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Lazarus, Jordan 1/3/2025 Asset Recovery Investigations Review

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analysis schedules. 1.2 \$ 621.00 Investigation and Litigation
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Parizek, Pam 1/6/2025 Asset Recovery Asset Analysis Review summary of post-petition inflows 2.3 \$ 1,637.60 Investigation and and Recovery (.5), working session with A. Lomas, J. Litigation Lazarus re: analysis of pre-petition

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account balances and post-petition inflows to
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(1.8). Lomas, Adam 1/6/2025 Asset Recovery Asset Analysis Meeting with L. Despins and P. Parizek 0.7 \$ 362.25 Investigation and and Recovery re: analysis.

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Litigation
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Parizek, Pam 1/6/2025 Asset Recovery Asset Analysis Preview draft Forfeiture order re: 0.3 \$ 213.60 Investigation and and Recovery email A. Lomas re: updated Litigation analysis (.3). Lomas, Adam 1/6/2025 Asset Recovery Asset Analysis Working meeting with P. Parizek and J. 1.8 \$ 931.50 Investigation and and Recovery Lazarus re:

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analysis and
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Litigation related funds tracing. Lomas, Adam 1/6/2025 Asset Recovery Asset Analysis Review updated forfeiture bill; related 0.6 \$ 310.50 Investigation and and Recovery updates to master transaction file and Litigation other reconciliations. Parizek, Pam 1/6/2025 Asset Recovery Asset Analysis Call with A. Lomas and Paul Hastings 0.7 \$ 498.40 Investigation and and Recovery (L. Despins) re:

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analysis
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Litigation (.5), debrief with A. Lomas re: same (.2).

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Timekeeper Date Matter Task Narrative Hours Amount

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Lomas, Adam 1/6/2025 Asset Recovery Asset Analysis Perform analysis and prepare related 4.9 \$ 2,535.75 Investigation and and Recovery schedule of postpetition outflows by Litigation bucket (i.e., suspected transfers to third

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parties, quantification of unknown withdrawals, transfers subject to avoidance actions, and transfers to
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Kwok-related accounts). Lazarus, Jordan 1/6/2025 Asset Recovery Investigations Phone call with A. Lomas and P. Parizek 1.0 \$ 517.50 Investigation and re: analysis schedules for

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discussion
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Litigation and related matters. Parizek, Pam 1/7/2025 Asset Recovery Asset Analysis Review supplemetal analysis of post 1.9 \$ 1,352.80 Investigation and and Recovery petition transfers (.5), call with A. Lomas Litigation and Paul Hastings re: same (1.0), debrief with A. Lomas re: analysis (.4). Lomas, Adam 1/7/2025 Asset Recovery Asset Analysis Meeting with L. Despins and P. Parizek 1.5 \$ 776.25

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Investigation and
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Litigation and Recovery re: postpetition outflows by bucket and analysis. Parizek, Pam 1/7/2025 Asset Recovery Asset Analysis Call with A. Lomas and Paul Hastings 1.5 \$ 1,068.00 Investigation and and Recovery (L. Despins, S. Maza) re: post-petition Litigation transfer analysis (1.5). Lomas, Adam 1/7/2025 Asset Recovery Asset Analysis Meeting with Paul Hastings [L. Despins 1.6 \$ 828.00 Investigation and and Recovery and S. Maza] re: analysis.

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Litigation
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Lomas, Adam 1/7/2025 Asset Recovery Asset Analysis Review of supplemental document 4.1 \$ 2,121.75 Investigation and and Recovery production with respect to previously

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Litigation identified unknown
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related updates to master transaction file. Lomas, Adam 1/8/2025 Asset Recovery Asset Analysis Meeting with T. Spier re: recent bank 0.6 \$ 310.50 Investigation and and Recovery productions and upcoming analyses and Litigation priorities. Spier, Tre 1/8/2025 Asset Recovery Asset Analysis Review of document productions from 3.5 \$ 771.75

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Investigation and and Recovery and Litigation and related updates to inventory of Debtor
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related bank accounts. Lomas, Adam 1/8/2025 Asset Recovery Asset Analysis Review of supplemental document 2.8 \$ 1,449.00 Investigation and and Recovery production with respect to previously

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Litigation identified unknown
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related updates to master transaction file. Spier, Tre 1/8/2025 Asset Recovery Asset Analysis Meeting with A. Lomas re: recent bank 0.6 \$ 132.30 Investigation and and Recovery productions and upcoming analyses and Litigation priorities. Lomas, Adam 1/8/2025 Asset Recovery Asset Analysis Meeting with Paul Hastings [L. Despins, 1.1 \$ 569.25 Investigation and and Recovery S. Maza, and D. Barron] re: Litigation analysis. Lomas, Adam 1/8/2025 Asset Recovery Asset Analysis Perform analysis and prepare related 0.6 \$ 310.50 Investigation and and Recovery schedule of postpetition inflows in all

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Litigation
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Parizek, Pam 1/8/2025 Asset Recovery Asset Analysis Call with A. Lomas and Paul Hastings 1.1 \$ 783.20 Investigation and and Recovery (L. Despins, S. Maza, D. Barron) re: Litigation forfeitures and post-petition transfer analysis (1.1). Lazarus, Jordan 1/8/2025 Asset Recovery Investigations Review correspondence from A. Lomas 0.2 \$ 103.50 Investigation and to NPM Law re: updated avoidance Litigation actions and related matters.

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Timekeeper Date Matter Task Narrative Hours Amount

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Parizek, Pam 1/8/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Re-read indictment and superceding indictments re:

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of forfeiture (1.0), draft forfeiture order (.3),
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Ater Ego Complaint (1.4). 2.7 \$ 1,922.40 Lazarus, Jordan 1/9/2025 Asset Recovery

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Investigation and
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Litigation Investigations Call with P. Parizek, A. Lomas, Paul Hastings (L. Despins, N. Bassett, D.

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Barron), and NPM Law [P. Linsey and K. Mitchell] re: bank account analysis, and related matters. 0.1 \$ 51.75 Lomas, Adam 1/9/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Review of supplemental document

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production with respect to previously identified unknown
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related updates to master transaction file. 1.8 \$ 931.50

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Barker, James 1/9/2025 Asset Recovery Investigation and
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Litigation Investigations Call with P. Parizek, A. Lomas, J. Lazarus, Paul Hastings (L. Despins, N. Bassett, D. Barron), and NPM Law [P.

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Linsey and K. Mitchell] re: bank account analysis, and related matters. 0.1 \$ 63.90 Lomas, Adam 1/9/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Meeting re: investigative updates with Paul Hastings [L. Despins, N. Bassett, D. Barron, and L. Song], NPM Law [P.

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Lisney and K. Mitchell], and P. Parizek and J. Lazarus. 0.1 \$ 51.75 Parizek, Pam 1/9/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review S. Maza analysis of (.2), compare A. Lomas lead sheet and to forfeiture (.9). 1.1 \$ 783.20 Spier, Tre 1/9/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Review of document productions from

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and and related updates to inventory of Debtor related bank accounts. 2.6 \$ 573.30 Lomas, Adam 1/10/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Review, clean-up, and reconciliation of

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data in preparation of updated transfer schedules for avoidance action decisioning. 6.7 \$ 3,467.25 Parizek, Pam 1/10/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Continued review and analysis of

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forfeiture accounts, third-party post petition transafers and (1.4) 1.4 \$ 996.80 Lomas, Adam 1/10/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Review of supplemental document

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production with respect to previously identified unknown
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related updates to master transaction file. 0.4 \$ 207.00

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Spier, Tre 1/10/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review and analysis of
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bank account transactions; related updates to master transaction file. 2.5 \$ 551.25

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Spier, Tre 1/10/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Review of document productions from

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and and related updates to inventory of Debtor related bank accounts. 3.3 \$ 727.65
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Timekeeper Date Matter Task Narrative Hours Amount

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Lomas, Adam 1/10/2025 Asset Recovery Asset Analysis Compose email to NPM Law [P. Linsey 0.3 \$ 155.25 Investigation and and Recovery and K. Mitchell] re:

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for Litigation and
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Lazarus, Jordan 1/10/2025 Asset Recovery Investigations Review correspondence between A. 0.2 \$ 103.50 Investigation and Lomas and NPM Law re: avoidance

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1/13/2025 Litigation
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Asset Recovery action schedules and related matters. Lomas, Adam Investigation and Asset Analysis and Recovery Attention to analysis/schedule of postpetition inflows in all 3.2 \$ 1,656.00

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Litigation
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Parizek, Pam 1/13/2025 Asset Recovery Asset Analysis Review A. Lomas summary of 0.1 \$ 71.20 Investigation and and Recovery (.1).

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Litigation
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Parizek, Pam 1/13/2025 Asset Recovery Asset Analysis Call with A. Lomas and S. Maza re: 2.8 \$ 1,993.60 Investigation and and Recovery forfeiture analysis (1.0), review and Litigation analysis of impacted bank account statements (1.1), confer A. Lomas re: same (.7). Jones, Iain 1/13/2025 UAE Asset Investigations Conduct Investigation regarding 2.0 \$ 1,278.00

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Recovery Actions
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Lazarus, Jordan 1/13/2025 General Debtor Fee/Employment Prepare December 2024 Monthly fee 0.8 \$ 414.00 Representation Applications statement and September through December 2024 fee application. Lomas, Adam 1/13/2025 Asset Recovery Asset Analysis Meeting with S. Maza, and P. Parizek re: 1.0 \$ 517.50 Investigation and and Recovery analysis.

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Lomas, Adam 1/13/2025 Litigation
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Asset Recovery Asset Analysis Review, clean-up, and reconciliation of 1.7 \$ 879.75 Investigation and and Recovery data in preparation of updated transfer Litigation schedules for avoidance action decisioning. Spier, Tre 1/13/2025 Asset Recovery Asset Analysis Review and analysis of 1.2 \$ 264.60 Investigation and and Recovery bank account transactions; Litigation related updates to master transaction file.

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Lomas, Adam 1/13/2025 Asset Recovery Asset Analysis Targeted analysis of postpetition activity 0.9 \$ 465.75 Investigation and and Recovery (ungrouping of deposits and withdrawals)

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Litigation in account; related updates to
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master transaction file. Parizek, Pam 1/14/2025 Asset Recovery Asset Analysis Review reservation of rights with respect 1.0 \$ 712.00 Investigation and and Recovery to preliminary forfeiture, call with A. Litigation Lomas re: same and verification of financial amounts (1.0). Lomas, Adam 1/14/2025 Asset Recovery Asset Analysis Respond to inquiry from Paul Hastings 0.1 \$ 51.75 Investigation and and Recovery [E. Sutton] re: certain transfers with

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Litigation respect to
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PC.

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Lomas, Adam 1/14/2025 Asset Recovery Asset Analysis Prepare schedule of updated transfer 6.4 \$ 3,312.00 Investigation and and Recovery totals to existing avoidance defendants; Litigation compose related email to NPM Law [P. Linsey and K. Mitchell]. Lomas, Adam 1/14/2025 Asset Recovery Asset Analysis Review, clean-up, and reconciliation of 2.2 \$ 1,138.50 Investigation and and Recovery data in preparation of updated transfer Litigation schedules for avoidance action decisioning.

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Timekeeper Date Matter Task Narrative Hours Amount

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Lomas, Adam 1/14/2025 Asset Recovery Asset Analysis Respond to inquiry from NPM Law [P. 0.2 \$

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103.50
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Investigation and and Recovery Linsey] re: confidentiality markings of Litigation documents supporting transfers to

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PC and
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LLP. Lazarus, Jordan 1/14/2025 Asset Recovery Investigations Review and respond to correspondence 0.7 \$

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362.25
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Investigation and with NPM Law re: numerous avoidance Litigation action claims and related matters. Lomas, Adam 1/15/2025 Asset Recovery Asset Analysis Revisions to schedule of transfers to 0.2 \$

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103.50
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Investigation and and Recovery existing avoidance defendants; related Litigation email to NPM Law [P. Linsey]. Parizek, Pam 1/15/2025 Asset Recovery Asset Analysis Prep call with A. Lomas re: forfeiture 0.5 \$

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356.00
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Investigation and and Recovery analysis (.5).

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Parizek, Pam 1/15/2025 Litigation
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Asset Recovery Asset Analysis Review breakdown of new post-petition 0.1 \$

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71.20
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Investigation and and Recovery funds (.1).

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Litigation
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Parizek, Pam 1/15/2025 Asset Recovery Asset Analysis Review A. Lomas summary of updated 1.0 \$

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712.00
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Investigation and and Recovery transfer totals for existing avoidance Litigation defendants (.3). Lomas, Adam 1/15/2025 Asset Recovery Asset Analysis Meeting with P. Parizek re: draft Paul 0.7 \$

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362.25
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Investigation and and Recovery Hastings

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Litigation
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Lomas, Adam 1/15/2025 Asset Recovery Asset Analysis Working meeting with Paul Hastings [S. 2.4 \$

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1,242.00 Investigation and
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Litigation and Recovery Maza and D. Barron] re: forfeiture analysis. Parizek, Pam 1/15/2025 Asset Recovery Asset Analysis Call with A. Lomas, S. Maza and D. 2.3 \$

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1,637.60
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Investigation and and Recovery Barron re: forfeiture analysis (2.3).

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Litigation
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Lomas, Adam 1/15/2025 Asset Recovery Asset Analysis Analysis of postpetition activity in 3.9 \$

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2,018.25
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Investigation and and Recovery network of commingled

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related Litigation and related bank accounts subject to seizure; respond to email inquiries from Paul Hastings [S. Maza]
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re: same. Lomas, Adam 1/15/2025 Asset Recovery Asset Analysis Review of draft Paul Hastings brief in 0.7 \$

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362.25
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Investigation and and Recovery connection with preliminary forfeiture; Litigation prepare related comments thereon. Parizek, Pam 1/15/2025 Asset Recovery Asset Analysis Review updated analysis of 0.4 \$

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284.80
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Investigation and and Recovery to forfeiture (.4).

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Litigation
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Parizek, Pam 1/15/2025 Asset Recovery Asset Analysis Review Trustee's Settlement Proposal 0.3 \$

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213.60
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Investigation and and Recovery regarding

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and related charts 1/15/2025 Litigation
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Asset Recovery (.3). Lomas, Adam Investigation and Asset Analysis and Recovery Attention to illustrative charts in support

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of Paul Hastings 3.8 \$ 1,966.50 Litigation
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Lazarus, Jordan 1/15/2025 Asset Recovery Investigations Review and respond to correspondence 0.8 \$

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414.00
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Investigation and with NPM Law re: numerous avoidance Litigation action claims and related matters. Lomas, Adam 1/16/2025 Asset Recovery Asset Analysis Meeting with NPM Law [P. Linsey] and 0.3 \$

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155.25
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Investigation and and Recovery Paul Hastings [D. Barron and L. Song] Litigation re: schedule of transfers for existing

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avoidance defendants and matters with respect to the
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Complaint.

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Timekeeper Date Matter Task Narrative Hours Amount

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Lomas, Adam 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Meeting re: data for avoidance action decisioning and forfeiture analysis, with Paul Hastings [L. Despins, N. Bassett, D. Barron, and L. Song], NPM Law [P. Lisney and K. Mitchell], and P. Parizek 0.6 \$

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310.50 Lomas, Adam 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Attention to illustrative charts in support

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of Paul Hastings 3.7 \$ 1,914.75 Lomas, Adam 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Respond to inquiry from NPM Law [K. Mitchell] re: current metrics with respect

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to and transactions; related calculations and analyses. 1.0 \$ 517.50 Spier, Tre 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review and analysis of
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bank account transactions; related updates to master transaction file. 2.0 \$

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441.00 Spier, Tre 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Source and verify inputs to chart of 3.0 \$

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661.50 Parizek, Pam 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review illustrations of related to forfeiture and to (.2). 0.2 \$ 142.40 Parizek, Pam 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Review updated summary of bank accounts and transaction volume (.1). 0.1 \$

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71.20 Lomas, Adam 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis
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and Recovery Instructions to T. Spier re: sourcing of

#
chart. 0.4 \$ 207.00 Parizek, Pam 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Call with A. Lomas and Paul Hastings re:

#
additional amounts collectiable from
#

avoidance defendants, forfeiture analysis

#
(.6). 0.6 \$ 427.20 Lomas, Adam 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Review of draft Paul Hastings PowerPoint deck re: forfeiture analysis. 0.6 \$

#
310.50 Parizek, Pam 1/16/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Review final draft of Presentation to

#
Government re: Fofeiture Settlement proposal, confirm accuracy of
#

calculations (.5); review appendix slides and A. Lomas explanation re: same (.3). 0.8 \$

#
569.60
#

Lazarus, Jordan 1/16/2025 Asset Recovery

#
Investigation and
#

Litigation Investigations Review and respond to correspondence

#
with NPM Law re: numerous avoidance
#

action claims and related matters. 0.4 \$

#
207.00 Lomas, Adam 1/17/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Attention to illustrative charts in support

#
of Paul Hastings 1.2 \$ 621.00 Lomas, Adam 1/17/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Revisions to schedule of transfers to

#
existing avoidance defendants. 1.8 \$ 931.50 Lomas, Adam 1/17/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Meeting with Paul Hastings [S. Maza

#
and D. Barron] re: comments on forfeiture analysis charts. 0.3 \$ 155.25 Parizek, Pam 1/17/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Review updated appendices to fofeiture

#
presentation (.2), S. Maza summary
#

analysis of outflows (.1), final review of forfeiture presentation deck (.3). 0.6 \$

#
427.20
#

Timekeeper Date Matter Task Narrative Hours Amount

#
Spier, Tre 1/17/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review and analysis of
#

bank account transactions; related updates to master transaction file. 2.5 \$

#
551.25 Lomas, Adam 1/20/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Revisions to schedule of updated transfer totals to existing avoidance defendants; compose related email to NPM Law [P.

#
Linsey and K. Mitchell] and Paul
#

Hastings [D. Barron and L. Song]. 0.8 \$

#
414.00
#

Lazarus, Jordan 1/21/2025 Asset Recovery

#
Investigation and
#

Litigation Investigations Review and respond to correspondence

#
with NPM Law re: numerous avoidance
#

action claims and related matters. 0.4 \$

#
207.00 Parizek, Pam 1/21/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Review A. Lomas calculation of revised

#
amounts due from avoidance defendants, additional transferees for avoidance actions (.3). 0.3 \$ 213.60 Lomas, Adam 1/21/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Prepare schedule of transferees not

#
currently included in existing avoidance action; compose related email to NPM
#

Law [P. Linsey and K. Mitchell]. 2.9 \$

#
1,500.75 Lomas, Adam 1/22/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Incorporate Inc bank account
#

transactions into master transaction file

#
for review/analysis. 0.4 \$ 207.00 Lomas, Adam 1/22/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Quality control review of
#

bank account transaction analysis; related updates to master transaction file. 0.6 \$

#
310.50 Lomas, Adam 1/22/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Quality control review of bank account transaction analysis; related updates to master transaction file. 0.7 \$ 362.25 Lomas, Adam 1/22/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Quality control review of bank account transaction analysis; related updates to master transaction file. 1.0 \$ 517.50 Lomas, Adam 1/22/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Upload of bank statements into bank

#
statement analysis tool. 0.1 \$ 51.75 Lomas, Adam 1/22/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review and analysis of bank account transactions; related updates to master transaction file. 1.9 \$ 983.25 Lomas, Adam 1/22/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Quality control review of
#

bank account transaction analysis; related updates to master transaction file. 0.5 \$

#
258.75 Barker, James 1/23/2025 Asset Recovery Investigation and
#

Litigation Investigations Call with A. Lomas, J. Lazarus, Paul Hastings (L. Despins, N. Bassett, D. Barron, L. Song), and NPM Law [P.

#
Linsey and K. Mitchell] re: bank account and avoidance action analysis updates and related matters. 0.4 \$ 255.60
#

Lazarus, Jordan 1/23/2025 General Debtor

#
Representation Fee/Employment
#

Applications Prepare December 2024 Monthly fee

#
statement and September through December 2024 fee application. 0.9 \$ 465.75
#

Timekeeper Date Matter Task Narrative Hours Amount

#
Lomas, Adam 1/23/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Compose email to Paul Hastings and

#
NPM Law counsel teams re: agenda for weekly status meeting; related meeting preparation. 0.4 \$ 207.00 Lomas, Adam 1/23/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Email to J. Barker re: planned

#
with respect to defendants. 0.2 \$ 103.50 Spier, Tre 1/23/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Review of document productions from

#
related updates to inventory of Debtor-related bank accounts. 0.7 \$ 154.35 Lomas, Adam 1/23/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Meeting with NPM Law [P. Linsey and

#
K. Mitchell] re: data for possible new and amended avoidance actions. 0.4 \$ 207.00 Lomas, Adam 1/23/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Respond to inquiries from NPM Law [K.

#
Mitchell and R. Flynn] re: documents underlying transfers to related
#

compilation of relevant bank documents. 1.2 \$

#
621.00
#

Lazarus, Jordan 1/23/2025 Asset Recovery

#
Investigation and
#

Litigation Investigations Review and respond to correspondence

#
with NPM Law re: numerous avoidance
#

action claims and related matters. 0.7 \$

#
362.25 Lomas, Adam 1/23/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Preliminary review of documents

#
produced by 0.2 \$ 103.50
#

Lazarus, Jordan 1/23/2025 Asset Recovery

#
Investigation and
#

Litigation Investigations Call with A. Lomas, J. Barker, Paul Hastings (L. Despins, N. Bassett, D. Barron, L. Song), and NPM Law [P.

#
Linsey and K. Mitchell] re: bank account and avoidance action analysis updates and related matters. 0.4 \$ 207.00 Lomas, Adam 1/23/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Meeting re: bank transaction analysis for

#
accounts and suspected " other investigative updates, with Paul
#

Hastings [L. Despins, N. Bassett, D. Barron, and L. Song], NPM Law [P. Linsey and K. Mitchell] and J. Barker. 0.4 \$

#
207.00 Lomas, Adam 1/23/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Revisions to schedule of transferees not

#
currently included in existing avoidance action (to separate transferees into requested buckets); compose related
#

email to NPM Law [P. Linsey and K.

#
Mitchell]. 2.2 \$ 1,138.50 Lomas, Adam 1/24/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review and analysis of LLC and
#

bank account transactions; related updates to master transaction file. 1.6 \$

#
828.00 Lomas, Adam 1/24/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Incorporate LLC and bank account transactions into master
#

transaction file for review/analysis. 0.3 \$

#
155.25 Lomas, Adam 1/24/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Respond to inquiry from Paul Hastings

#
[L. Song] re: transfers with respect to and/or related
#

document and transaction review. 0.6 \$

#
310.50
#

Timekeeper Date Matter Task Narrative Hours Amount

#

Lomas, Adam 1/24/2025 Asset Recovery Asset Analysis Respond to inquiry from NPM Law [P. 0.2 \$

#
103.50
#

Investigation and and Recovery Linsey] re: number of bank accounts Litigation identified since July 2024. Lomas, Adam 1/27/2025 Asset Recovery Asset Analysis Review and analysis of 0.4 \$

#
207.00
#

Investigation and and Recovery bank account Litigation transactions; related updates to master transaction file. Parizek, Pam 1/27/2025 Asset Recovery Asset Analysis Review schedules to December fee 0.7 \$

#
498.40 Investigation and
#

Litigation and Recovery statement and narrative redactions (.7). Lomas, Adam 1/27/2025 Asset Recovery Asset Analysis Review and analysis of 0.5 \$

#
258.75
#

Investigation and and Recovery bank account transactions; Litigation related updates to master transaction file.

#

Lomas, Adam 1/27/2025 Asset Recovery Asset Analysis Incorporate

#
bank 0.2 \$ 103.50
#

Investigation and and Recovery account transactions into master Litigation transaction file for review/analysis. Lomas, Adam 1/27/2025 Asset Recovery Asset Analysis Incorporate 0.6 \$

#
310.50 Investigation and and Recovery Litigation and bank account transactions into master transaction file for
#

1/27/2025 General Debtor review/analysis. Lazarus, Jordan Representation Fee/Employment Applications Prepare December 2024 Monthly fee

#
statement and September through 1.3 \$ 672.75
#

December 2024 fee application. Lomas, Adam 1/27/2025 Asset Recovery Asset Analysis Upload of bank statements into bank 1.7 \$

#
879.75
#

Investigation and and Recovery statement analysis tool.

#
Litigation
#

Lomas, Adam 1/27/2025 Asset Recovery Asset Analysis Reconciliation of bank statements 2.1 \$

#
1,086.75
#

Investigation and and Recovery received compared to those analyzed Litigation and/or processed through bank statement analysis tool to date. Lomas, Adam 1/27/2025 Asset Recovery Asset Analysis Review and analysis of 0.2 \$

#
103.50
#

Investigation and and Recovery bank account transactions; related Litigation updates to master transaction file. Parizek, Pam 1/27/2025 Asset Recovery Asset Analysis Review A. Lomas updates re: financial 0.3 \$

#
213.60 Investigation and
#

Litigation and Recovery analysis, J. Barker updates re: (.3). Lomas, Adam 1/28/2025 Asset Recovery Asset Analysis Upload of bank statements into bank 0.2 \$

#
103.50
#

Investigation and and Recovery statement analysis tool.

#
Litigation
#

Lomas, Adam 1/28/2025 Asset Recovery Asset Analysis Incorporate

#
and 0.4 \$ 207.00 Investigation and and Recovery bank
#

Litigation account transactions into master transaction file for review/analysis. Lomas, Adam 1/28/2025 Asset Recovery Asset Analysis Review and analysis of 0.5 \$

#
258.75 Investigation and and Recovery and
#

Litigation bank account transactions; related updates to master transaction file.

#

Lomas, Adam 1/28/2025 Asset Recovery Asset Analysis Review and analysis of correspondent 2.9 \$

#
1,500.75
#

Investigation and and Recovery wire transfer information provided by

#
Litigation related reconciliation and
#

updates to master transaction file. Lomas, Adam 1/28/2025 Asset Recovery Asset Analysis Incorporate

#
bank account 0.2 \$ 103.50
#

Investigation and and Recovery transactions into master transaction file Litigation for review/analysis.

#

Timekeeper Date Matter Task Narrative Hours Amount

#
Lomas, Adam 1/28/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Review of additional documents

#
produced by related update of inventory of Debtor-related bank accounts. 1.1 \$ 569.25 Lomas, Adam 1/28/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Incorporate and bank account transactions into master transaction file for review/analysis. 0.3 \$ 155.25 Lomas, Adam 1/28/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review and analysis of bank account transactions; related updates to master transaction file. 1.3 \$ 672.75 Lomas, Adam 1/29/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Updates to schedules of transfers to

#
existing avoidance defendants and (to provide additional information with respect to timing of
#

composed related email to NPM Law [P.

#
Linsey]. 1.4 \$ 724.50 Lomas, Adam 1/29/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Staff supervision re: review and analysis

#
of and bank account transactions. 0.3 \$ 155.25 Spier, Tre 1/29/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review and analysis of and bank account transactions; related
#

updates to master transaction file. 3.9 \$ 859.95

#
Lomas, Adam 1/29/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Internal email to Kroll team re:

#
for complaints; related
#

correspondence with X. Pallas re: 0.7 \$ 362.25 Lazarus, Jordan 1/29/2025 Asset Recovery

#
Investigation and
#

Litigation Investigations Review and respond to correspondence

#
with NPM Law re: numerous avoidance
#

action claims and related matters. 0.3 \$ 155.25

#
Barker, James 1/29/2025 Asset Recovery Investigation and
#

Litigation Investigations Correspondence/email - updated L.Song

#
on 2.0 \$ 1,278.00 Parizek, Pam 1/29/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Review research re:

#
(.1). 0.1 \$ 71.20 Lomas, Adam 1/30/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Updates to schedules of transfers to

#
existing avoidance defendants and (to provide additional information with respect specific effectuating transfers); composed related
#

email to NPM Law [P. Linsey and D.

#
Skalka]. 1.1 \$ 569.25
#

Timekeeper Date Matter Task Narrative Hours Amount

#
Lomas, Adam 1/30/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Meeting re: bank account analysis for

#
certain related accounts at public records research with respect to and and other investigative updates; with Paul Hastings [L. Despins, N. Bassett, D. Barron, and L. Song], NPM Law [P. Linsey], and P. Parizek and J. Barker. 0.5 \$ 258.75 Parizek, Pam 1/30/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Call with A. Lomas, Paul Hastings (L.

#
Despins, N. Bassett, D. Barron, L. Song)
#

and NPM Law (P. Linsey) re:

#
accounts at public records research, new and amended avoidance actions (.5). 0.5 \$ 356.00 Spier, Tre 1/30/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review and analysis of and bank account transactions; related
#

updates to master transaction file. 1.5 \$ 330.75 Lazarus, Jordan 1/30/2025 Asset Recovery

#
Investigation and
#

Litigation Investigations Review and respond to correspondence

#
with NPM Law re: numerous avoidance
#

action claims and related matters. 0.4 \$ 207.00

#
Parizek, Pam 1/30/2025 General Debtor Representation Fee/Employment
#

Applications Review draft fee application (.2). 0.2 \$ 142.40

#
Barker, James 1/30/2025 Asset Recovery Investigation and
#

Litigation Investigations Call with A. Lomas, P. Parziek, Paul Hastings (L. Despins, N. Bassett, D. Barron, L. Song) and NPM Law (P. Linsey) re:

#
accounts at public records research, new and amended avoidance actions (.5). 0.5 \$ 319.50 Spier, Tre 1/31/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Meeting with A. Lomas re: review and

#
sourcing of schedules of transfers for complaints. 0.3 \$ 66.15 Lomas, Adam 1/31/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Prepare schedules of transfers for complaints. 4.4 \$ 2,277.00
#

Lazarus, Jordan 1/31/2025 General Debtor

#
Representation Fee/Employment
#

Applications Prepare and review September through December 2024 fee application. 1.8 \$ 931.50

#
Spier, Tre 1/31/2025 Asset Recovery Investigation and Litigation Asset Analysis and Recovery Review and analysis of and bank account transactions; related updates to master transaction file. 2.1 \$ 463.05 Parizek, Pam 1/31/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Review list of new transferees and

#
updated avoidance claims for existing transferees (.3). 0.3 \$ 213.60 Spier, Tre 1/31/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Review and source schedules of

#
transfers for complaints. 5.2 \$ 1,146.60 Lomas, Adam 1/31/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Meeting with T. Spier re: review and

#
sourcing of schedules of transfers for complaints 0.3 \$ 155.25 Lomas, Adam 1/31/2025 Asset Recovery Investigation and Litigation Asset Analysis
#

and Recovery Staff supervision re: review and analysis

#
of and
#

bank account transactions. 0.2 \$ 103.50 Total Hours and Amount: 202.4 \$ 100,527.45

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