Guo Wengui / Miles Guo — bankruptcy case · ECF #4154

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re: :

HO WAN KWOK, et al., : :

Debtors.1 :

------------------------------------------------------ x COVERSHEET FOR FIFTH INTERIM FEE APPLICATION OF HARNEY WESTWOOD & RIEGELS LP

Interim Application of: Harney Westwood & Riegels LP

Time Period: September 1, 2024 through December 31, 2024 Bankruptcy Petition Filed: February 15, 2022 (main bankruptcy case) Date of Entry of Retention Orders: October 3, 2022 [ECF No. 909] (effective as of July 31, 2022, as to Individual Debtor), January 4, 2023 [ECF No. 1247] (effective as of November 21, 2022, as to Genever (BVI)), and May 28, 2024 [ECF No. 3219] (effective as of

Fees: \$836,530.00 Voluntary Fee Reductions: \$00.00 Expenses: \$18,054.71 Voluntary Expenses Reductions: none

Fees Previously Requested: Retainer Request:

Expenses Previously Requested: Expense Detail: Requested Expenses: \$82,843.07 Retainer Received: Not applicable Awarded Expenses: \$82,843.07 Copies per page cost & total: 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). UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re: :

HO WAN KWOK, et al., :

Debtors.1 :

**FIFTH INTERIM FEE APPLICATION OF HARNEY WESTWOOD & RIEGELS LP, AS BRITISH VIRGIN ISLANDS AND CAYMAN ISLANDS COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM SEPTEMBER 1, 2024 THROUGH DECEMBER 31, 2024**

Pursuant to sections 105(a), 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 Order"), Harney Westwood & Riegels LP ("Harneys" or the "Applicant"), (a) as British Virgin Islands ("BVI") and Caymans Islands counsel to Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Individual Debtor") and (b) as BVI counsel to Genever Holdings Corporation ("Genever

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 the 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).

(BVI)"), hereby files this *Fifth Interim Application of Harneys Westwood & Riegels LP., as British Virgin Islands and Cayman Islands Counsel, for Compensation and Reimbursement of Expenses for the Period from September 1, 2024 through December 31, 2024* (the

"Application"). By this Application, Harneys requests interim allowance of professional fees incurred during the period from September 1, 2024 through and including December 31, 2024 (the "Application Period") in these chapter 11 cases. In support of this Application, Harneys 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. Harneys 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 Harneys 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:

2 Harneys 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.

- Exhibit A contains the Proposed Order granting this Application. - Exhibit B is a timekeeper summary that includes the name, title, bar admission, hourly billing rate, aggregate hours, and amount of fees earned for each Harneys individual who provided services during the Application Period; - Exhibit C is a summary of expenses incurred and reimbursement sought, by expense type, during the Application Period; and - Exhibit D contains the detail of the fees and expenses incurred during the Application Period.

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 October 3, 2022, the Court authorized Harney's retention as BVI counsel for the Trustee [Docket No. 669] effective as of July 31, 2022 in the Individual Debtor's chapter 11 case. The Retention Order authorizes Harneys 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.

10. 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.

11. By order entered May 28, 2024, the Court expanded Harney's retention to also serve as Cayman Islands counsel for the Trustee [Docket No. 3219] (together with the retention orders with respect to BVI-related services for the Trustee and Genever (BVI) [Docket Nos. 669 and 1286], the "Retention Order"), effective as of April 10, 2024.

12. On October 11, 2022, Genever (BVI) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

13. No trustee, examiner, or official committee of unsecured creditors has been appointed in Genever (BVI)'s chapter 11 case.

14. October 14, 2022, the Court entered an order granting joint administration of the Individual Debtor's chapter 11 case and Genever (BVI)'s chapter 11 case [ECF No. 970].

15. On January 4, 2023, the Court granted Genever (BVI)'s application to retain Harneys as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., November 21, 2022 [ECF No. 1286].

16. On October 16, 2023, Harneys filed its *First Interim Fee Application of Harney Westwood & Riegels LP, as British Virgin Islands Counsel, for Compensation and Reimbursement of Expenses for Period From July 31, 2022 Through July 31, 2023* [Docket No. 2259] (the "First Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from July 31, 2022 through and including July 31, 2023 in these chapter 11 cases.

17. On November 30, 2023, the Court granted the First Interim Fee Application.

18. On February 19, 2024, Harneys filed its *Second Interim Fee Application of Harney Westwood & Riegels LP, as British Virgin Islands Counsel, for Compensation and Reimbursement of Expenses for Period From August 1, 2023 Through December 31, 2023* [Docket No. 2259] (the "Second Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from August 1, 2023 through and including December 31, 2023 in these chapter 11 cases.

19. On March 20, 2024, the Court granted the Second Interim Fee Application.

20. On June 24, 2024, Harneys filed its *Third Interim Fee Application of Harney Westwood & Riegels LP, as British Virgin Islands Counsel, for Compensation and Reimbursement of Expenses for Period From January 1, 2024 Through April 30, 2024* [Docket No. 3280] (the "Third Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from January 1, 2024 through and including April 30, 2024 in these chapter 11 cases.

21. On July 26, 2024, the Court granted the Third Interim Fee Application.

22. On October 15, 2024, Harneys filed its *Fourth Interim Fee Application of Harney Westwood & Riegels LP, as British Virgin Islands Counsel, for Compensation and Reimbursement of Expenses for Period From May 1, 2024 Through August 31, 2024* [Docket No. 3693] (the "Fourth Interim Fee Application" and, together with the First Interim Fee Application, the Second Interim Fee Application, and the Third Interim Fee Application, the

"Prior Interim Fee Applications"), requesting interim allowance of professional fees incurred during the period from May 1, 2024 through and including August 31, 2024 in these chapter 11 cases.

23. On November 13, 2024, the Court granted the Fourth Interim Fee Application.

24. The Applicant is applying for compensation pursuant to sections 330 and 331 of the Bankruptcy Code for legal services performed for the Trustee and Genever (BVI) during the Application Period.

25. For the Application Period, the Applicant seeks allowance of \$836,530.00 as compensation for services rendered as BVI and Cayman counsel and allowance and reimbursement of \$18,054.71 in expenses incurred in connection with such services.

26. The Applicant devoted 894 hours to this case during the Application Period, equating to an overall blended rate of \$922.10.

27. Harneys did not submit any monthly fee statements during the Application Period, and, accordingly, by this Application, Harneys is requesting allowance and payment of the full amount of fees and expenses incurred during the Application Period.

28. Throughout the Application Period, the Applicant maintained records to indicate the name of each attorney or paraprofessional 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.

29. Annexed hereto and made a part hereof as Exhibit D is a detailed billing report, upon which this application is based that contains each individual professional's time for the

Debtors' bankruptcy proceedings, 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 dollar value of such services.

30. During the Application Period, Harneys continued to provide legal services as BVI counsel to the Trustee, including advice for bankruptcy, litigation, investigations, real estate, tax, and other matters.

31. As detailed in Harneys' Prior Interim Fee Applications, upon being formally instructed, Harneys took immediate steps on behalf of the Trustee to obtain various disclosure orders from the BVI court related to BVI registered agents as part of the Trustee's efforts to investigate the Debtors' financial affairs, including his ownership of assets through family, friends, and affiliates. These disclosure orders have established that the Debtor's affiliates have violated the Bankruptcy Code's automatic stay and have transferred the ownership of companies owned by the Debtor to keep the companies outside of the Trustee's control. During the Application Period, Harneys continued to provide legal services as BVI counsel to the Trustee, including advice for bankruptcy, litigation, investigations, real estate, tax, and other matters.

32. Harneys provided general advice to the Trustee on complex matters with regards to establishing ownership of two Debtor-related entities (namely Ace Decade Holdings Limited (Ace Decade) and Dawn State Limited (Dawn State)). Harneys advised on complex matters with regards to establishing ownership of Ace Decade, inter alia, steps to assist with the recovery of the Ace Decade share, including commencing substantive proceedings under Part XIX of the BVI Insolvency Act, 2003, and undertook extensive research to advise on the

enforceability of judgments, the rectification of register of members, and the restoration of the BVI companies purportedly owned by the Debtor.

33. Harneys also advised the Trustee with respect to the appointment of joint liquidators Alvarez & Marsal in the BVI liquidation proceedings for Ace Decade and Dawn State, the impact of such BVI liquidations on these chapter 11 cases, and drafted submissions in the BVI liquidations with respect to the joint liquidators' jurisdiction and powers in relation to the share register for these BVI entities. Harneys also made submissions at the hearing of the joint liquidators' directions application on December 18, 2024.

34. Harneys also provided general advice to the Trustee on several other complex matters related to the Trustee's efforts to recover property of the estate, including the recovery of a luxury apartment in London nominally held by a BVI company purportedly owned by the Debtor's son. On September 30, 2024, Harneys assisted the Trustee with bringing substantive proceedings to recover assets of the estate (including preparing substantive evidence, claim documents, strategy notes and legal arguments). Harneys will continue to act for the Trustee in these proceedings, which have been listed for trial in November 2025. Further, Harneys advised the Trustee in detail with respect to private international law issues concerning the enforcement of U.S. judgments in the BVI.

35. No prior application for the relief requested has been made. And, as noted, Harneys has not received any payment of the fees incurred during the Application Period.

36. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee and Genever (BVI) in connection with the chapter 11 cases herein.

37. The Applicant respectfully submits that its services have benefited the Trustee and Genever (BVI) with the expertise and skill required in the handling of bankruptcy matters. The legal services for which such compensation is requested were performed for and on behalf of the Trustee and Genever (BVI). Such services have been necessary to protect and enforce the rights and interests of the Trustee and Genever (BVI) in connection with these chapter 11 cases. The reasonable value of services rendered by Harneys in these cases is based upon Harneys usual hourly rates for matters of this nature.

38. 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.

39. 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).3

3 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

40. 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).

41. 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., 4 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

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).

4 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.

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

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

43. No agreement or understanding exists between Harneys and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. Harneys will not, in any form or guise, share or agree to share compensation for services with any person, nor will Harneys 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.

5 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).

44. 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 Harneys has for any reason not sought compensation or reimbursement with respect to such services, Harneys reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these chapter 11 cases. Additionally, Harneys 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.

45. No previous request for the relief sought herein has been made to this Court or any other court.

[Remainder of page intentionally left blank.]

WHEREFORE, Harneys respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation, and authorizing and directing prompt payment, for professional services rendered during the Application Period in the amount of \$836,530.00 and reimbursement of \$18,054.71 in expenses, (ii) allowing such compensation and payment for professional services rendered without prejudice to Harneys' right to seek further compensation and/or payment from the estates for the full value of services performed and expenses incurred, and (iii) granting Harneys such other and further relief as is just.

Andrew Thorp HARNEY WESTWOOD & RIEGELS LP Craigmuir Chambers, PO Box 71, Road Town, Tortola VG1110, British Virgin Islands Telephone: 1 284 852 2571 Email: Andrew.thorp@harneys.com

British Virgin Islands and Cayman Islands Counsel to Luc A. Despins, Chapter 11 Trustee, and Genever Holdings Corporation 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 foregoing application (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 Debtors' chapter 11 cases. 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.

Dated: February 24, 2025 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) 318-6079 alexbongartz@paulhastings.com douglassbarron@paulhastings.com

Counsel for the Chapter 11 Trustee, Genever Holdings LLC, and Genever Holdings Corporation

Case 22-50073 Doc 4154 Filed 02/24/25 Entered 02/24/25 18:34:16 Page 17 of 53

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

In re: :

HO WAN KWOK, et al., : :

Debtors.1 : :

------------------------------------------------------------- x **[PROPOSED] ORDER GRANTING FIFTH INTERIM FEE APPLICATION OF HARNEY WESTWOOD & RIEGELS LP, AS BRITISH VIRGIN ISLANDS AND CAYMAN ISLANDS COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM SEPTEMBER 1, 2024 THROUGH DECEMBER 31, 2024**

Upon consideration of the Application (the "Application") of Harney Westwood &

Riegels ("Harneys") as BVI2 and Cayman Islands counsel to the Trustee and Genever (BVI) for

interim allowance of compensation and reimbursement of expenses from September 1, 2024

through December 31, 2024 (the "Application Period"); 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 for the Application, it is hereby:

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

as set forth herein and compensation in the amount of \$836,530.00 and reimbursement of

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 the 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.

expenses in the amount of \$18,054.71 are awarded to Harneys, 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 Harneys' fees and expenses in the aggregate amount of \$854,584.71 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 Debtors' estates and Harneys 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 4154 Filed 02/24/25 Entered 02/24/25 18:34:16 Page 20 of 53

September 1, 2024, through December 31, 2024

TIMEKEEPER DATE OF TITLE HOURS HOURLY TOTAL

Andrew Thorp 1998 Partner 84.20 \$1,300.00 \$109,460.00 Colin Riegels 1996 Partner 1.40 \$1,300.00 \$1,820.00 Peter Farrer 1998 Partner 5.80 \$1,300.00 \$7,540.00 Marcia McFarlane 2007 Partner 24.20 \$1,300.00 \$31,460.00 George Weston 2010 Partner 3.20 \$1,300.00 \$4,160.00 Jeremy Child 2003 Partner 10.80 \$1,175.00 \$12,690.00 Natalie Lee 2013 Counsel 8.80 \$1,015.00 \$8,932.00 James Petkovic 2012 Counsel 112.60 \$1,045.00 \$115,266.00 Andre McKenzie 2017 Senior Associate 0.20 \$910.00 \$182.00 Jhneil Stewart 2018 Senior Associate 502.80 \$910.00 \$452,998.00 Rhonda Brown 2011 Associate 5.60 \$910.00 \$3,086.00 Priya Mattu 2018 Associate 0.20 \$590.00 \$118.00 Isobel McNaught 2021 Associate 101.00 \$590.00 \$73,278.00 Mairead Dinneen 2023 Associate 6.00 \$590.00 \$3,609.00 Aurelia Matonis 2022 Associate 26.20 \$590.00 \$11,8951.00

Administrative support professional's time effecting service on BVI Companies

Alnessa Davis-Morris Legal Secretary 2.4 \$275.00 \$660.00

Payment of Costs (Disclosures from BVI Registered Agent) \$13.257.50

Case 22-50073 Doc 4154 Filed 02/24/25 Entered 02/24/25 18:34:16 Page 22 of 53

Jhneil Stewart 02/09/2024 Ace decade: Reviewing material for proposed strategy (1.00); Considering underlying material, strategy and next steps for

of insolvency adverts (0.20); considering case law and research points and drafting strategy note (4.60); email to AMT re ; call with Campbells re Ace Decade (0.20); discussion with AMT re Ace Decade and next steps (0.40); email to AMT (0.20).` ` 910 7.60 6,916.00 Jhneil Stewart 03/09/2024 Considering client's email (0.20); email to AMT re cost budget (0.20; email to client re Stat Note and proposed next steps (0.20); discussing WP position with AMT re Maples (0.40); collating and reviewing underlying evidence re Qiang Guo such as securities of commission compliant (2.60); considering note on nature of injunction in view of K Disclosure (0.60) drafting evidential points for affidavit (4.2) 910 8.40 7,644.00 Andrew Thorp 03/09/2024 Updated advice and opinion to Paul Hastings on interim relief and Part

Andrew Thorp 03/09/2024 Review of disclosure affidavit and commentary 1300 0.20 260.00 Andrew Thorp 03/09/2024 Considering strategy and jurisdiction for 1300 2.40 3,120.00 Andrew Thorp 03/09/2024 Mails to Palas lawyers re K Legacy situation 1300 0.40 520.00 Jhneil Stewart 04/09/2024 Ace decade: Further review of evidence and drafting evidence for injunction and discussing points with AMT (8.0); call with Campbells re Ace Decade (0.20); email to AMT re Ace Decade (0.20); email to Campbells re Trustee's position (0.20); 910 8.60 7,826.00 Jhneil Stewart 05/09/2024 Call with Alex and AMT re next steps (1.00); discussing next steps and evidential points with AMT following call with client re instructions to issue BVI proceedings (1.00); email to IMC re next steps re insolvency publications (0.20); draft email to AMT re email to Maples (0.20); reviewing file to provide update on status of excel chart (0.20) email to Alex re summary of proceedings etc. (0.20); incorporating evidential points in draft affidavit and email to AMT re point raised by client (5.00); email to Maples re disclosure (0.20; considering

Jhneil Stewart 05/09/2024 Emails re corp bill 0 0.40 Marcia McFarlane 05/09/2024 Attended to reviewing email updates and status of norwich pharmacal relief from 3 to 30 August 2024 1300 0.80 1,040.00 Jhneil Stewart 06/09/2024 Dawn state: Email to AMT re cross undertaking position (0.20); Drafting injunction application docs (application; certificate of urgency etc) 3.60; reviewing affidavit from Campbell's; uploading docs to share drive with client and updating client (0.60) 910 4.40 4,004.00 Marcia McFarlane 06/09/2024 Update with JQS on evidence drafted for injunction and proceedings to

George Weston 09/09/2024 Drafting letter for Blue Capital (0.40); briefing Rhonda (0.40), further review and email to Rhonda (0.20) 1300 1.00 1,300.00 Rhonda Brown 09/09/2024 Drafting letter to Walkers re filing notice of release. 550 1.00 590.00 Marcia McFarlane 09/09/2024 Dawn state: Reviewed draft application, certificate of urgency and draft order seeking urgent injunctive relief against redomicile of K Legacy and dissipating assets (1.4) Reviewed the supporting affidavit for urgent 1300 3.00 3,900.00

injunction with client comments (0.8) Discussed with JQS client updates to affidavit (0.2) Re NPO re salamander, reviewed draft response to Maples on undertaking in damages request (0.4) Reviewed letter to Ace Decade JLs re intention to settle list of members in the name of the

Jhneil Stewart 09/09/2024 Dawn state: Considering next steps (0.40); Email to team re suite of application docs and next steps (0.80); drafting draft letter from PH to Walkers and email to team re same(0.60); call with AMT re next steps and draft email to client re Maples request (0.80); consider and amend notice, draft order and COU (1.20); further call with AMT and updated email to client re undertaking (0.60); Instructions with AMT and drafting letter to Campbell's (1.20); email to client re draft injunction docs (0.20);

with AMT re client call and proposed next steps and drafting email to client re points on draft order etc (1.40) 910 8.40 7,644.00 George Weston 10/09/2024 call with Alex re letter 1300 0.20 260.00 Isobel McNaught 10/09/2024 Preparation of exhibit LD‐1 590 5.80 ‐ Marcia McFarlane 10/09/2024 Reviewed updates to the evidence to address ; (0.4) reviewed draft correspondence to Campbells (0.2); addressed the issue of the cross undertaking in damages for the norwich pharmacal

Jhneil Stewart 10/09/2024 Drafting skeleton argument and collating docs for exhibit and email to

Jhneil Stewart 10/09/2024 Email to client and AMT re letter to Campbells (0.40); Drafting draft statement of claim (2.00); call with AMT re next steps (0.40); emails to clients re Maples undertaking instructions (0.40) 910 3.20 2,912.00 Jhneil Stewart 10/09/2024 Emails re next steps for prohibitory injunction (0.80); call with client re draft docs and team update to IMC on exhibit and next steps (1.20); amends and further draft of evidence (1.00); Discussing next steps with IMC and updating letter to Campbells; email to AMT re cross undertaking email to client (0.40) 910 3.40 3,094.00 George Weston 11/09/2024 brief Rhonda on call from Alex (0.40); review letter as redrafted and comment (0.40); email correspondence regarding letter (0.40) 1300 1.20 1,560.00 Rhonda Brown 11/09/2024 Internal correspondence with George Weston re updating letter (0.20); finalising letter to lender re release of pledge (0.40); arranging delivery of letter (0.40); email to Walkers Corporate Limited (0.20); internal correspondence (0.20); email to director re attempts at delivery (0.20). 550 1.60 944.00 Isobel McNaught 11/09/2024 Consideration of correspondence concerning settling list of members 590 0.20 118.00 Marcia McFarlane 11/09/2024 Update with JQS on status of documents for filing urgent application for freezing order; assist with work to be done on the skeleton (0.4); reviewed updated application for injunctive relief, locate

Rev ewed updates to the application for injunctive relief (0.4) 1300 3.60 4,680.00 Marcia McFarlane 11/09/2024 Reviewed the draft skeleton supporting the freezing injunction relief 1300 1.40 1,820.00 Isobel McNaught 11/09/2024 Liaising with Paul Hastings with documents from previous exhibits 590 0.40 236.00 Isobel McNaught 11/09/2024 Updating exhibit LD‐1 590 6.20 ‐

Jhneil Stewart 11/09/2024 Instructions re exhibit (0.40); emails to AMT re next steps (0.20); call with client re instructions and next steps and email update and discussions with team re same (1.80); instructions re company search (0.20); instructions re checks for Gazette publication (0.20); email updates to team re Gazette results and status of company (0.40); drafting skeleton arguments (2.80); finalizing draft claim docs (0.80); call with AMT and reviewing draft exhibit and finalizing draft injunction application docs (2.20;) discussion with counsel re hearing prep (0.20); email to AMT re same (0.20); email to client re suite of docs and next steps (0.40); discussions and email to MAM re Omnibus Alter Ego complaint and BVIi claim (0.40) 910 10.20 9,282.00

Jhneil Stewart 12/09/2024 Consider numerous authorities on (1:00), discussion with MAM, call with AMT on nominee agreement and alternative points and further updates to skeleton and emails to James Morgan re skeleton (1.00) and drafting supplemental affidavit and exhibit and instructions re updated authorities

Jhneil Stewart 12/09/2024 Reviewing draft listing request 910 0.20 182.00 Jhneil Stewart 12/09/2024 Considering and attending to emails from James Morgan re strategy;

Jhneil Stewart 12/09/2024 Emails re authorities bundle and making amends to AB index (0.40); instructions re next steps (0.20) 910 0.60 546.00 Jhneil Stewart 12/09/2024 Considering various points and making amends to draft skeleton, application notice and order (3.20) making client proposed inserts to affidavit and finalizing same for swearing(0.40); email to client re filing (0.20); instructions re filing (0.20) 910 4.00 3,640.00 Jhneil Stewart 12/09/2024 Internal discussion with JBP re hearing prep, email to JBP re filed docs

Jhneil Stewart 12/09/2024 Call with AMT re strategy and claim (0.40); email to James Morgan re docs; instructions to team re attendances for JM requests (0.40) 910 0.80 728.00 Marcia McFarlane 12/09/2024 Update with JQS on amends to the affidavit, issue of

to the submissions addressing the issue of

Andrew Thorp 12/09/2024 Review and completion of pleading, originating application and urgent

Andrew Thorp 12/09/2024 Briefing counsel re pleading , form, jurisdiction and background 1300 0.80 1,040.00 Isobel McNaught 12/09/2024 Finalising documents for filing and filing 590 0.60 354.00 Isobel McNaught 12/09/2024 Preparation of listing request form 590 0.20 118.00 Isobel McNaught 12/09/2024 Sending documents to Counsel 590 0.20 118.00 Isobel McNaught 12/09/2024 Consideration of correspondence from James Morgan regarding

Isobel McNaught 12/09/2024 Consideration of ordinary application and draft order 590 0.40 236.00 Isobel McNaught 12/09/2024 Consideration of claim form and statement of claim 590 0.40 236.00 Isobel McNaught 12/09/2024 Amending draft Order 590 0.20 118.00 Isobel McNaught 12/09/2024 Preparation of authorities bundle and updates to skeleton 590 2.20 ‐ Isobel McNaught 12/09/2024 Preparation of hearing bundle 590 0.40 236.00 Marcia McFarlane 13/09/2024 Injunction submissions‐ attended to Counsel's comments on the submissions and liaised with JQS to address them (1.0) Further attendances to Counsel's updated comments on the submissions‐ attended to matters arising from the exhibits (0.6) 1300 1.60 2,080.00 Andrew Thorp 13/09/2024 Considering position with respect to 1300 0.40 520.00

Jhneil Stewart 13/09/2024 Dawn state: Numerous emails and discussions with IMC and MAM re next steps and supporting evidence (1.60); call with AMT re skeleton and attending to James Morgan queries on skeleton and evidence (2.00); reviewing draft hearing bundle (0.20); reviewing evidence and affidavit to update counsel queries in skeleton (3.00); discussion with JBP re hearing prep (0.40); emails to AMT and Counsel re draft skeleton (0.40); email to Campbells re Ace Decade (0.20); email re instructions (0.20) 910 8.00 7,280.00

Isobel McNaught 13/09/2024 QC Review of LD‐1 and liaising with JQS 590 4.00 2,360.00 Isobel McNaught 13/09/2024 Cross referencing 590 0.80 ‐ Jhneil Stewart 14/09/2024 Reviewing draft authorities and hearing bundle and making further amends to skeleton; emails to team re same 910 1.20 1,092.00 Isobel McNaught 14/09/2024 QC preparation of hearing bundle hard copy for JBP 0 1.40 ‐ Isobel McNaught 14/09/2024 Cross referencing skeleton (continued) (0.5) and updating authorities

Isobel McNaught 15/09/2024 Updating cross‐references in skeleton and liaising with team regarding 590 0.60 354.00 Andrew Thorp 15/09/2024 Review of submissions from counsel and commentary team merits of

Jhneil Stewart 15/09/2024 Reviewing James Morgan further amends to skeleton (0.3) and

James Petkovic 15/09/2024 Working on speaking note. 1045 4.40 4,466.00 Rhonda Brown 16/09/2024 Email correspondence with director; email to client providing update. 550 0.20 118.00 James Petkovic 16/09/2024 Further work on speaking notes (1.5), reviewing skeleton (0.5) and reviewing draft SoC over the course of the day(2.5) 1045 4.00 4,060.00 Jhneil Stewart 16/09/2024 Considering strategy and next steps and circulating action list/step plan

Jhneil Stewart 16/09/2024 Emails to James Morgan re skeleton and evidence (0.40); consider and attend to query from JM KC re the effect of breach of the Automatic Stay (0.40); reviewing and making amends to updated skeleton from JM KC (2.00); discussion with AMT and JBP re full and frank, terms of draft

and drafting proposed paragraph (1.00);

(0.40); emails to client re supplemental affidavit

, email re same and reviewing and considering with JBP (0.60); email to JBP re summary of disclosure and current status from RA (0.60); email to team re seal and gag point (0.20); instructions re filing LD‐2; discussing pleading point with AMT and skeleton (0.20); email to client re instructions on skeleton (0.20); call with client re amend s re

discussing same with Andy via email and call considering material non‐ disclosure point (1.20); email to client re final skeleton (0.20); reviewing draft SOC and considering insolvency and CPR rules (1.60) 910 9.40 8,554.00 Andrew Thorp 16/09/2024 Emails with Paul Hastings re 1300 0.20 260.00 Andrew Thorp 16/09/2024 Considering evidence, form of order and 1300 1.20 1,560.00 Andrew Thorp 16/09/2024 Instructions to counsel to consider

Marcia McFarlane 16/09/2024 Updated on amendments made the injunction draft order and updates to the unlawful transfer position (0.2) Discussed with JQS wording for submissions on full and frank where risk of forfeiture greater than a risk of re‐domicilation ‐ why the relief is still required (0.4) Further tweaks to the submissions (0.2) Considered the insolvency act and CPR regarding the new claim to be issued (0.2) 1300 1.00 1,300.00 Isobel McNaught 16/09/2024 Updating hearing bundle, authorities bundle and skeleton argument 590 1.00 590.00 Isobel McNaught 16/09/2024 Consideration of action list 590 0.20 118.00

Isobel McNaught 16/09/2024 Review of Despins 2, finalising and filing 590 0.80 472.00

Isobel McNaught 16/09/2024 Consideration of correspondence concerning prohibitory injunction 590 0.40 236.00 Rhonda Brown 17/09/2024 Email to sole director 550 0.20 118.00 Isobel McNaught 17/09/2024 Filing of skeleton argument, hearing bundle and authorities bundle 590 1.40 826.00 Isobel McNaught 17/09/2024 Liaising with team regarding listing of hearing and diarising and consideration of next steps 590 0.40 236.00 Jhneil Stewart 17/09/2024 Considering emails, internal team discussion re email from court on hearing date, next steps and the claim(0.80; email to team re recommendation in light of email from court (0.20); emails to James Morgan re injunction (0.40); instructions to IMC re filings (0.40); email update to client re filings (0.20); updating action list (0.40); emails to AMT and client re proposed call (0.40); circulating dial in (0.20); comprehensive review of IR rules and CPR rules and authorities and preparing step plan for claim (4.20); discussion with MAM re Insolvency Rules (1.00) calls with JBP re strategy (0.40); email to AMT re strategy

Marcia McFarlane 17/09/2024 Considered with JQS the process for issuing the claim and coordinating with the injunction hearing set for 1 Oct 2024 to secure a return date for both applications to be heard together in light of the insolvency act and the civil procedure rules and confirmed final advice to the team (1.0) 1300 0.60 780.00 James Petkovic 17/09/2024 Further work on speaking note (1.5) and also discussing case with wider Harneys team as to next steps (0.7). 1045 2.20 2,233.00 George Weston 18/09/2024 Emails with Claire and Rhonda re next steps 1300 0.40 520.00 Rhonda Brown 18/09/2024 Email correspondence with director re execution of declaration. 550 0.20 118.00 Jhneil Stewart 18/09/2024 Reviewing file and updating draft injunction order (0.60); Consider email from Maples and send email to AMT re same (0.20); Discussion with AMT re next steps (0.40); Email to Maples re cross ‐ undertaking in damages (0.20); Discussing application strategy with MAM (0.40); Brief review of evidence re status of forfeiture proceedings (claim etc) (0.20); Update action list of work streams (0.20); Email to AMT re meeting agenda (0.40); discussion with AMT re proposed call and instructions (0.40); email to IMC re draft evidence (0.20); Call with clients re claim and internal discussions with AMT and IMC re next steps, amends to originating application/points of claim, considering IR and including further order (2.20); Considering CPR rules re expedited trial and drafting email to team re same (0.60); considering various evidential points for evidence and email to team re same (0.40) 910 6.40 5,824.00 Andrew Thorp 18/09/2024 Dealing with cross undertaking and costs re salamander disclosure

Andrew Thorp 18/09/2024 Conference call with Paul Hastings re position (0.4) and amendments to Statement of claim, further discussion regarding urgency and

Andrew Thorp 18/09/2024 Conference re strategy and deployment of US disclosure 1300 0.40 520.00 Andrew Thorp 18/09/2024 Considering timetable/ strategy and advising on filing deadlines 1300 0.60 780.00 Andrew Thorp 18/09/2024 Detailed review and comments on originating application and points of

Isobel McNaught 18/09/2024 Call with Paul Hastings regarding statement of claim, and follow‐up discussion with AMT and JQS 590 0.60 354.00 Jhneil Stewart 19/09/2024 Drafting draft order and proposed directions for trial (1.60) Call with client re nominee agreement and discussion with AMT re same and brainstorming proposed wording (1.40); drafting email to JM re clients queries on OA (0.40); circulating updated drafts to client (0.20); brief review of deposition and email to team re same (0.20; Emails with AMT re Maples request for undertaking (0.40); discussion with IMC re

Andrew Thorp 19/09/2024 Considering case re 1300 0.60 780.00

Jhneil Stewart 19/09/2024 Emails to JBP re draft claim docs (0.20); email to James Morgan re amends and attending to queries re same (0.60); email to AMT re evidential point re transcript (0.20); email to James Morgan re insert to draft OA (0.20); drafting email to client re proposed strategy and finalizing application docs (1.20); email to AMT re Maples undertaking (0.20); email to client re same (0.20); email to AMT re response to

Andrew Thorp 19/09/2024 Advising on deployment of deposition in supporting evidence for

Andrew Thorp 19/09/2024 Email to maples re cross undertaking and costs, limited disclosure and

Andrew Thorp 19/09/2024 Review of advice on directions and opining on strategy and timing of claim issuance, considering potential for summary judgment and case law with respect to 1300 0.80 1,040.00 Isobel McNaught 20/09/2024 Liaising with support team regarding checking for advertisement in Beacon and Gazette of BVI companies 590 0.20 118.00 Isobel McNaught 20/09/2024 Preparation of affidavit 590 0.80 472.00 Andrew Thorp 20/09/2024 Detailed review of relief and

changes to applicable law and introduction of US bankruptcy law to English proceedings. Effect of declaratory relief on English proceedings and bono vacantia (2.0) 1300 2.40 3,120.00 Marcia McFarlane 20/09/2024 Updated on strategy being adopted for the claim (0.2), reviewed the Wood v Baker case, reviewed analysis by JQS on application of foreign

Jhneil Stewart 20/09/2024 Emails to JM re PoC (0.40); considering foreign law issues with AMT, considering queries from JM re foreign law and alter ego principles and considering numerous authorities and preparing comprehensive

in support of OA with IMC (0.20); email to AMT re draft email to client re JM query on alter ego principles(0.20) 910 8.40 7,644.00 Andrew Thorp 22/09/2024 Conference with counsel re 1300 0.60 780.00 Andrew Thorp 22/09/2024 Considering 1300 1.40 1,820.00 Marcia McFarlane 23/09/2024 Reviewed counsel email on amendments made to the points of dispute 1300 0.40 520.00 Jhneil Stewart 23/09/2024 Email from James re POC 910 0.20 182.00 Jhneil Stewart 24/09/2024 Consider and attend to email from AMT re 910 0.40 364.00 Marcia McFarlane 24/09/2024 Reviewed the draft order to accompany the declaratory relief claim and

Isobel McNaught 24/09/2024 Updating draft affidavit of Luc Despins 590 1.40 826.00 Isobel McNaught 24/09/2024 Liaising with Mrs Chambers regarding listing of hearing 590 0.20 118.00 Jhneil Stewart 24/09/2024 Email re pre-bill 0 0.20

Jhneil Stewart 24/09/2024 Consider summary analysis from James KC re declaration re shares and Property (0.40); email to AMT re next steps (0.20); emails to IMC re hearing time and draft evidence (0.40); reviewing clients comments on PoC and considering James queries (0.40); discussing next steps with AMT (0.40); drafting letter to Quijano re K Legacy shareholding (1.00); email to JBP re points for full and frank for injunction hearing (0.20); email to JBP re update to speaking notes (0.20); drafting LOR and making amends to draft order (0.60); consider strategy email from AMT to James KC (0.20); email to JBP on status of London Apt and further update to speaking notes points (0.20); call with JBP re hearing prep and attending to query re effect of s146 notice and email to JBP re same

and email to AMT re same (0.40) 910 5.00 4,550.00

Jhneil Stewart 24/09/2024 Reviewing all pre‐bills and finalizing narratives 0 2.00 ‐ Andrew Thorp 24/09/2024 Email on re 1300 0.20 260.00 Andrew Thorp 24/09/2024 Further advice re 1300 0.60 780.00

Jhneil Stewart 25/09/2024 Considering and attending to James Morgan query re , considering authorities and discussing with AMT and finalizing draft POC and drafting covering email to clients 910 1.80 1,638.00 Isobel McNaught 25/09/2024 Consideration of correspondence regarding points of claim 590 0.20 118.00 Isobel McNaught 25/09/2024 Further updating affidavit in support of interim relief 590 2.60 1,534.00 Marcia McFarlane 25/09/2024 Reviewed and suggested amendment to the points of claim to deal with

Jhneil Stewart 25/09/2024 Trawling file for parties list of interest and emails to team re same 0 1.20 ‐ Jhneil Stewart 25/09/2024 Emails to AMT re letter to Quijano and proposed wording re seal and gag 910 0.40 364.00 Jhneil Stewart 25/09/2024 Reviewing Despins 3 and email to IMC re comments 910 0.80 728.00 Jhneil Stewart 25/09/2024 Drafting covering email to client on letter to Quijano and email to Alex re same (0.20); email to Quijano serving letter (0.20); email update to client and JBP (0.20); matter management (0.20) 910 0.80 728.00 Jhneil Stewart 25/09/2024 Email to clients re revised POC 910 0.20 182.00 Priya Mattu 25/09/2024 reviewing file to locate parties list 550 0.20 118.00 Jhneil Stewart 26/09/2024 Considering authority on 910 1.60 1,456.00 Jhneil Stewart 26/09/2024 Considering BCA on effect of discontinuance in the BVI, considering enforceability point with IMC and email to JBP re same 910 0.40 364.00 Jhneil Stewart 26/09/2024 Considering emails re liquidation notices 910 0.20 182.00 Jhneil Stewart 26/09/2024 Brief consideration of additional full and frank point and email to JBP re updated draft order and update to full and frank points; 910 0.40 364.00 Jhneil Stewart 26/09/2024 Email update to client on hearing time 910 0.20 182.00 Jhneil Stewart 26/09/2024 Reviewing draft Despins 3 and drafting further evidence; considering language for relief with AMT and circulating wording to IMC; instructions to IMC re evidence and relying on US orders 910 3.60 3,276.00 Jhneil Stewart 26/09/2024 Emails re parties list of interest and drafting covering email to Doug 0 0.40 ‐ Jhneil Stewart 26/09/2024 Considering facts and principles on 910 0.60 546.00 Jhneil Stewart 26/09/2024 Ace decade: Chaser email to client re POC and update on Ace Decade directions application 910 0.20 182.00 Jhneil Stewart 26/09/2024 Consider clients amends on POC, considering strategy with AMT and updating same and evidence 910 1.40 1,274.00

Marcia McFarlane 26/09/2024 Advised on the issue of ; reviewed pleading on 1300 0.40 520.00

Andrew Thorp 26/09/2024 Review of detailed affidavit in support of originating application, edits and dealing with the reproofing of US default orders 1300 1.60 2,080.00 Andrew Thorp 26/09/2024 Acde decade: Conference call with liquidators lawyers re settling list,

Isobel McNaught 26/09/2024 Updating affidavit in response to comments and updates. 590 1.40 826.00 Isobel McNaught 26/09/2024 Consideration of

liaising with team regarding 590 0.40 236.00 Isobel McNaught 26/09/2024 Preparation for hearing of proprietary injunction: Call to Court regarding listing of hearing, liaising with support team re hard copy bundles for

Andrew Thorp 26/09/2024 Considering strategy, relief and disclosure provisions in affidavit. Completing Points of claim and coordinating with interim injunction relief. Dealing with power of surrender and vesting provisions. 1300 1.20 1,560.00 Jhneil Stewart 27/09/2024 Considering next steps in light of clients email on recent developments 910 0.20 182.00 Jhneil Stewart 27/09/2024 Strategy with AMT re claim and clients query and drafting email to client

Jhneil Stewart 27/09/2024 Considering JM KC and attending to JM comments on draft evidence in support of OA and emailing revised draft to team 910 1.80 1,638.00 Jhneil Stewart 27/09/2024 Email to counsel on update from client 910 0.20 182.00 Jhneil Stewart 27/09/2024 Email to AMT re email to client re order from Maples (0.40); reviewing Maples costs schedule and draft order and circulating comments POD to

Jhneil Stewart 27/09/2024 Reviewing list and drafting covering email to AMT re email to James

Jhneil Stewart 27/09/2024 Finalizing affidavit and emailing draft to client 910 0.40 364.00 Jhneil Stewart 27/09/2024 Emails and strategy discussion with JBP re ownership of K Legacy 910 0.40 364.00 Jhneil Stewart 27/09/2024 Considering next steps and email to AMT re next steps on list (0.40); 910 0.40 364.00 Jhneil Stewart 27/09/2024 Email to client re PH latest schedule of parties in interest 910 0.20 182.00 Jhneil Stewart 27/09/2024 Consider and attend to JM query on evidence and email to team re same 910 0.20 182.00 Jhneil Stewart 27/09/2024 Instructions to IMC re Despins 3 and hard copy hearing bundle for the

Jhneil Stewart 27/09/2024 Considering and attending to JM latest comments on POC and email to AMT re current position 910 0.40 364.00 James Petkovic 27/09/2024 Updating speaking note in the light of developments since I last prepared for this hearing. 1045 5.00 5,225.00 Isobel McNaught 27/09/2024 Preparation for hearing on prohibitory injunction: liaising with JBP regarding hearing bundle references, collating documents to bring to

Isobel McNaught 27/09/2024 Liaising with JBP regarding transfer of funds from Debtor to fund

Andrew Thorp 27/09/2024 Ace decade: Call with Campbells for application and next steps to be

Andrew Thorp 27/09/2024 Ace decade: Email update re Ace Decade and liquidators skeleton

Andrew Thorp 27/09/2024 Review of affidavit evidence, commentary and edits, sending to clients 1300 1.40 1,820.00 Marcia McFarlane 27/09/2024 Considered with JQS the norwich pharmacal order amended on behalf of SHRM for removal of paragraphs 4 and para 5 and amendments to the

Andrew Thorp 28/09/2024 Emails with PH team re 1300 0.40 520.00

Isobel McNaught 29/09/2024 Preparation of exhibit to Despin 3. 590 2.40 1,416.00 James Petkovic 29/09/2024 Working on and rehearsing speaking note ahead of the hearing and preparing for injunction hearing. 1045 5.40 5,643.00 James Petkovic 30/09/2024 Amends to speaking note in the light of factual changes over course of

Jhneil Stewart 30/09/2024 Consider and attend to client's query re K Legacy's shareholding;

Jhneil Stewart 30/09/2024 Reviewing draft exhibit and instructions to IMC re exhibit and affidavit 910 0.60 546.00 Jhneil Stewart 30/09/2024 Hearing preparation and instructions to team re hearing 910 0.60 546.00 Jhneil Stewart 30/09/2024 Email to JBP re and proposed amends to draft order 910 0.20 182.00 Jhneil Stewart 30/09/2024 Consider and respond to client email re confidential docs 910 0.20 182.00 Jhneil Stewart 30/09/2024 Brief review of underlying docs circulated by client; consider and attend to clients email re redactions 910 0.40 364.00 Jhneil Stewart 30/09/2024 Considering strategy and next steps and email to team re same 910 0.20 182.00 Jhneil Stewart 30/09/2024 Consider underlying documents, emails re same and email to client re exhibit LD-3 (1.00); consider recent developments with team and update affidavit (1.00); drafting introductory paragraph re merging applications (0.80); email re applicable CPR rules (0.40); finalizing originating application, draft order and points of dispute for filing (0.80); considering and attending to JBP queries re HK restraint order (0.60); email to James Morgan clerk (0.20); email to client re bankruptcy code provisions (0.20); email to team re relevant order (0.20); email instructions re filing deadline (0.40); strategy conference with AMT on evidence (0.40); draft email to client on proposed strategy (0.40); filing claim docs and email update re same (0.40); email to counsel re evidence (0.20); emails to team and client re HK proceedings (0.40); email to client and counsel with filed docs (0.20); email to JBP re client's position on the HK order (0.20); emails and instructions to IMC re exhibit (0.40); reviewing JBP speaking notes (0.80); consider and attend to email from Quijano (0.20); email to client re same (0.20); preparing draft supplemental hearing bundle (0.40); preparing exhibit cover sheet (0.20) 910 10.00 9,100.00 Jhneil Stewart 30/09/2024 Drafting service letters and authorization codes 910 0.80 728.00 Isobel McNaught 30/09/2024 Additions to Exhibit LD-3 590 1.40 826.00 Isobel McNaught 30/09/2024 Updating exhibit 590 3.20 1,888.00 Marcia McFarlane 30/09/2024 Assisted with language for updating supporting evidence to reflect how

(0.2) Assisted with determining available dates for both originating application and return date hearing of injunction.

Rhonda Brown 30/09/2024 Email correspondence with client; email to director. 550 0.20 118.00 Marcia McFarlane 01/10/2024 post injunction hearing - considered email approach for dealing with edits to affidavit evidence already filed, comments on service letters to enclose injunction documents and reviewed email to the court enclosing the injunction order as granted 1300 0.40 520.00 Isobel McNaught 01/10/2024 Preparation for hearing (including printing hard copy documents to hand up) and follow-up from hearing (including ordering transcript, liaising with Mrs Chambers re listing, updating hearing note, updating letter of service, preparing share folder for service) 590 2.40 1,416.00 Jhneil Stewart 01/10/2024 Instructions to team re Despins 4 910 0.20 182.00

Jhneil Stewart 01/10/2024 Email to IMC re conviction order 910 0.20 182.00

Jhneil Stewart 01/10/2024 Emails re hearing prep, hearing prep (reviewing material etc and instructions re next steps) 910 1.40 1,274.00 Jhneil Stewart 01/10/2024 Consider and diarising deadline 910 0.20 182.00 Jhneil Stewart 01/10/2024 Emails to team and client re affidavit (0.40); updating service letters, draft letter to notify third parties (1.40); summary email to AMT and clients on hearing (0.40) 910 2.20 2,002.00 Jhneil Stewart 01/10/2024 Reviewing exhibit and instructions to IMC re same 910 0.80 728.00 Jhneil Stewart 01/10/2024 Con stat with AMT and IMC re hearing prep; 910 0.40 364.00 Jhneil Stewart 01/10/2024 Email to James clerk re conflicts update 0 0.20 Jhneil Stewart 01/10/2024 Further hearing prep re supplemental hearing bundle; Attending hearing and post hearing strategy and logistics (service prep, updating draft order, instructions re securing return date, email to team and court re

Andrew Thorp 01/10/2024 Detailed preparation and instruction of counsel for hearing 1300 2.00 2,600.00 Andrew Thorp 01/10/2024 Ace decade: Call with Campbells re position and skeleton argument on

Andrew Thorp 01/10/2024 Approving draft order and arranging service on relevant parties 1300 0.40 520.00 Andrew Thorp 01/10/2024 Emailing hearing outcome to clients 1300 0.20 260.00 Isobel McNaught 01/10/2024 Updating affidavit and exhibit and preparing covering affidavit 590 2.60 1,534.00 James Petkovic 01/10/2024 Final amends to speaking note and rehearsing application pre-hearing; attending hearing and making application; amending draft order and note of hearing after hearing. 1045 3.40 3,553.00 Rhonda Brown 01/10/2024 Email correspondence (0.20) ; arranging notarisation (0.20). 550 0.40 236.00 Isobel McNaught 02/10/2024 Preparations for service 590 0.60 354.00 Colin Riegels 02/10/2024 Ace decade: Review of skeleton; review and analysis of application of decision to BVI; consideration of 1300 1.40 1,820.00 Jhneil Stewart 02/10/2024 Considering next steps and emails to the court re approved order 910 0.40 364.00 Jhneil Stewart 02/10/2024 Reviewing docs for Despins 4 and commence draft of same 910 3.00 2,730.00 Jhneil Stewart 02/10/2024 Instructions re preparation for service in anticipation of approved order; drafting covering emails and finalizing notification letters; instructions re iManage links and reviewing documents uploaded for service 910 1.80 1,638.00 Jhneil Stewart 02/10/2024 Conference and instructions to IMC re next steps and continuation

Jhneil Stewart 02/10/2024 Ace decade: Strategy with AMT re Ace Decade', considering IA rules in view of JLS change of position, consider email from Pallas (1.60); Stat with AMT re Maples position, considering case law, drafting proposed email to client and proposed email to Maples (1.00) 910 2.60 2,366.00 Andrew Thorp 02/10/2024 Ace decade: Detailed analysis of

of members and rectification, drawing in Singaporean authority and further analysis of recent case law 1300 1.20 1,560.00 Rhonda Brown 02/10/2024 Email to Alex Buongartz providing update. O 0.20 Rhonda Brown 02/10/2024 Email to client re signed statutory declaration. 550 0.20 118.00 Andrew Thorp 03/10/2024 Calls with Pallas for UK proceedings, stay and UBS position, agreeing on

Marcia McFarlane 03/10/2024 Re follow up with Court for the approved injunction order, suggested wording for email to the court. 1300 0.40 520.00 Jhneil Stewart 03/10/2024 Consider and attend to query re client's appointment order 910 0.20 182.00 Jhneil Stewart 03/10/2024 Consider billing query from James clerks and email to AMT re same;

Jhneil Stewart 03/10/2024 Drafting skeleton points for Despins 4 910 1.60 1,456.00

Jhneil Stewart 03/10/2024 Email to client re next steps, strategy with AMT and IMC, arranging soft copy and hard copy service and notification of injunction order (including sending several emails notifying of order), finalizing, filing and arranging sealing of perfected order, email update to client re service 910 2.00 1,820.00 Jhneil Stewart 03/10/2024 Email chaser to court re injunction order (0.20); consider email from client on recent developments and email to team re strategy (0.20); updates to Despins 4 with further developments 910 0.60 546.00 Jhneil Stewart 03/10/2024 Considering next steps with AMT (0.20); con with IMC re next steps (0.20); updating and circulating strategy/action list (0.40) 910 0.80 728.00 Isobel McNaught 03/10/2024 590 0.60 354.00 Rhonda Brown 03/10/2024 Email to client attaching statutory declaration; emails. 550 0.40 236.00 Andrew Thorp 04/10/2024 Review of Quijano letter and mistaken application for share issuance 1300 0.20 260.00 Isobel McNaught 04/10/2024 Drafting points of dispute in response to Maples schedule. 590 1.00 590.00 Jhneil Stewart 04/10/2024 Ace decade: Consider and attend to query from Pallas re Ace Decade 910 0.40 364.00 Jhneil Stewart 04/10/2024 Review draft points of dispute by IMC and instructions re proposed

Jhneil Stewart 04/10/2024 Reviewing underlying docs and drafting Despins 4. 910 4.40 4,004.00 Jhneil Stewart 04/10/2024 Considering law on costs and email to team re same; emails to team re

Rhonda Brown 04/10/2024 Emails. O 0.20 Andrew Thorp 04/10/2024 Final review of evidence and additional evidence in relation to originating application against K Legacy 1300 0.80 1,040.00 Andrew Thorp 04/10/2024 Review of HK orders for restraint and application to evidence for

Jhneil Stewart 07/10/2024 Brief discussion with AMT re strategy meeting and circulating action list

Jhneil Stewart 07/10/2024 Considering numerous underlying documents provided by client and summarizing docs and further drafting of Despins 4 and evidence for continuation application. 910 5.80 5,278.00 Rhonda Brown 07/10/2024 Email to Alex Bongartz at Paul Hastings confirming filing (0.20); receipt and review of Certificate of Release and dispatching same (0.20). 550 0.40 236.00 George Weston 07/10/2024 Conference with R Brown (0.20): review emails from Alex (0.20) 1300 0.40 520.00 Jhneil Stewart 08/10/2024 Reviewing service and notification letter for injunction order and instructions to IMC re same 910 0.20 182.00 Jhneil Stewart 08/10/2024 Considering next steps (0.20); strategy meeting with AMT, JBP and IMC (1.40); email to IMC re sealed order (0.20); preparing list of strategic

Jhneil Stewart 08/10/2024 Ace decade: Email to JBP re submissions and next steps for Ace Decade 910 0.40 364.00 Jhneil Stewart 08/10/2024 Ace decade: Consider Campbells draft submissions and next steps re Ace

Jhneil Stewart 08/10/2024 Emails re fee application; discussions with Billy re cost schedules 910 0.40 364.00 Jhneil Stewart 08/10/2024 Ace decade: Preparing strategy note respect to regaining ownership of Ace Decade, email to AMT re same, considering IA Act and case law with AMT in light of JLs position and email to client re proposed strategy 910 2.60 2,366.00 Isobel McNaught 08/10/2024 Service of sealed order on all parties. 590 0.60 354.00 Isobel McNaught 08/10/2024 Ace decade: Kwok - internal discussion regarding workstreams 590 1.40 826.00 Isobel McNaught 09/10/2024 Affidavit of service 590 2.40 1,416.00

Jeremy Child 09/10/2024 Ace decade; Considering documents sent on from BVI team concerning upcoming hearing and Trustee submissions 1175 1.00 1,175.00

Jhneil Stewart 09/10/2024 Call with clients re Originating Application and next steps and email to

Jhneil Stewart 09/10/2024 Consider client query on BVI law re G Club motion to dismiss adversary

Jhneil Stewart 09/10/2024 Ace decade: Consider next steps for Ace Decade claim and attend to

Jhneil Stewart 09/10/2024 Matter management (0.20); email to client re service of sealed order and

Jhneil Stewart 09/10/2024 Strategy re evidence for Despins 4 and further draft of same 910 0.60 546.00 Jhneil Stewart 09/10/2024 Ace decade: Evidence for Ace Decade OA (3.00); emails to JCC re strategy and next steps (1.00); considering email from JBP re (0.20); call and email to client re next steps for injunction application

Jhneil Stewart 09/10/2024 Preparing Certificate of Urgency and revising listing request in light of

Jhneil Stewart 09/10/2024 Email to BWB re fee application (0.20); matter management (0.20); email to IMC re affidavit of service 910 0.60 546.00 James Petkovic 09/10/2024 Ace decade: Reading into

decision) raised by Campbells. 1045 2.00 2,090.00 Jhneil Stewart 10/10/2024 Email to client re notice of hearing (0.20); instructions to IMC re next

Jhneil Stewart 10/10/2024 Drafting injunction continuation application 910 0.60 546.00 Jeremy Child 10/10/2024 Ace decade: Considering JLs submissions and application papers, providing email advising team on points which should be made in

Jhneil Stewart 10/10/2024 Drafting evidence for Despins 4 (1.20); call with court re listing of originating application and matter attendances re same (0.40) 910 1.60 1,456.00 Isobel McNaught 10/10/2024 Hearing notice in diaries for counsel. 590 0.20 118.00 Natalie Lee 10/10/2024 Reviewing draft research; providing comments with respect to argument, presumption of advancement in response to US

Andrew Thorp 11/10/2024 Updating Pallas and setting out note re timing and JL submissions. 1300 0.80 1,040.00 Isobel McNaught 11/10/2024 Draft letters serving hearing notice 590 0.20 118.00 Isobel McNaught 11/10/2024 Liaising with JQS regarding steps taken to serve K Legacy and preparation of hard copies for service 590 0.40 236.00 Jhneil Stewart 11/10/2024 Ace decade: Drafting evidence for Ace Decade claim 910 0.40 364.00 Jhneil Stewart 11/10/2024 Ace decade: Considering IA rules and BCA on settling list of members vs register and circulating comments on JL skeleton 910 0.40 364.00 Jhneil Stewart 11/10/2024 Ace decade: Several emails to Pallas re Ace Decade and status update. 910 0.40 364.00 Jhneil Stewart 11/10/2024 Draft order for continuation application and finalizing of documents 910 1.80 1,638.00 Jhneil Stewart 11/10/2024 Consider Ogier letter and next steps, drafting response letter and arranging dispatch of hard copies, emails with team re strategy and next steps and email update to client 910 3.20 2,912.00 Jeremy Child 11/10/2024 Ace decade: Considering

Cayman case law and updating skeleton argument. 1175 2.00 2,350.00 Andrew Thorp 11/10/2024 Ace decade: Detailed review of law and response to JLs application re settling list of members, redraft of submissions and deconstructing

Andrew Thorp 11/10/2024 Considering 1300 0.40 520.00 Alnessa Davis‐Morris 11/10/2024 Preparing bundles and attending to service on K Legacy c/o Ogier. 275 1.00 275.00

Jhneil Stewart 11/10/2024 Ace decade: Considering JCC comments re interpretation of list of members and considering next steps 910 0.20 182.00

Jhneil Stewart 11/10/2024 Ace decade: Discussion with AMT re next steps for claim and strategy. 910 0.20 182.00 James Petkovic 14/10/2024 Reviewing and sending comments on Jhneil's draft continuation

James Petkovic 14/10/2024 Ace decade: Conference with legal team; considering strategy and developing plan for clients. 1045 1.00 1,045.00 Jeremy Child 14/10/2024 Ace decade: Considering amends to JLs skeleton and other comments to make on behalf of trustee, BVI team call to discuss the same and

Isobel McNaught 14/10/2024 Ace decade: Call regarding list and register of members 590 0.60 354.00 Isobel McNaught 14/10/2024 Drafting letter of service (hearing notice) 590 0.60 354.00 Jhneil Stewart 14/10/2024 Ace decade: Consider next steps and action email re meeting (0.20); Drafting Despins 1 for Ace Decade (5.20); Strategy call with AMT, JCC, JBP and IMC re Ace Decade (0.80); instructions to IMC re service of hearing notice and reviewing service letter (0.20); consider and email AMT re Pallas draft email (0.20); email to IMC re AOS 910 6.80 6,188.00 Jhneil Stewart 14/10/2024 Consider and attend to JBP proposed amends to K Legacy continuation application, discuss next steps with AMT and email to client re draft docs, collating documents for Despins 4 910 2.40 2,184.00 Isobel McNaught 15/10/2024 Consideration of amendments to affidavit of service 590 1.40 826.00 Jeremy Child 15/10/2024 Ace decade: Considering amends to JLs' submissions by BVI team 1175 1.00 1,175.00 Jeremy Child 15/10/2024 Ace decade: Considering Trustee draft submissions 1175 0.80 940.00 Andrew Thorp 15/10/2024 Ace decade: Review and commentary on skeleton argument (1.0) and pressing Campbells for filing and listing (0.2). 1300 1.20 1,560.00 Andrew Thorp 15/10/2024 Ace decade: Meeting with Campbells re progress and instructions re filing and next steps 1300 1.60 2,080.00 Andrew Thorp 15/10/2024 Email to PH re FFP and director provisions 1300 0.40 520.00 Natalie Lee 15/10/2024 Considering follow up queries re 1015 1.00 1,015.00 Jhneil Stewart 15/10/2024 Reviewing and amending draft Affidavit of Service; instruction to IMC re

Jhneil Stewart 15/10/2024 Download disclosure evidence, reviewing same and updating the PH

Jhneil Stewart 15/10/2024 Ace decade: Further drafting evidence for Ace Decade claim. 910 0.80 728.00 James Petkovic 15/10/2024 Ace decade: Amending skeleton (Walkers and ours in the light of further points), writing cover email to Walkers re further points (2 hours); reviewing and amending service affidavit for continuation application

Jhneil Stewart 15/10/2024 Ace decade: Consider JCC and JBP proposed comments to JL skeleton; proposed comments to team re 910 1.00 910.00 Jhneil Stewart 15/10/2024 Ace decade: Drafting points of claim for OA (Ace Decade) 910 2.00 1,820.00 Rhonda Brown 15/10/2024 Email correspondence with Sophie Fry of Mubadala Capital re letter to Blue Capital Limited (0.20) and email to client (0.20) 550 0.40 236.00 Jhneil Stewart 16/10/2024 Attending to Maples emails re costs, finalizing costs schedule, email to client re instructions and responding to Maples (0.6); finalising 4th affidavit of Luc (0.4); emails re updates to affidavit of service in light of

re Despins 3 and 4 making amends to same, collating docs for Despins 4 (1.2) and email to client re same, amends to continuation application, consider and attend to video evidence query (0.80). 910 3.00 2,730.00

Mairead Dinneen 16/10/2024 Drafted certificate of exhibit and proof-read exhibit (0.6), suggested changes in tracked changes (0.4). Liaised with Jhneil and AMT re incorporating videos into the exhibit (0.8). Drafted email for AMT for Jhneil's review. Saved documents down to desktop for exhibit. Considered exhibits which started with the same number to determine in which order the exhibit should take. (0.2) 590 2.00 1,210.00

Natalie Lee 16/10/2024 Continuing research; considering follow up queries re preparing responses. 1015 2.40 2,436.00 Marcia McFarlane 16/10/2024 Advice on issue of adducing video evidence before the court 1300 0.20 260.00 Andrew Thorp 16/10/2024 Ace decade: Advising PH re timing of Ace decade and liquidator applications, setting out timeline and decision tree. 1300 0.60 780.00 Andrew Thorp 16/10/2024 Detailed opinion re

lsobel McNaught 16/10/2024 Continuation application: Preparation of exhibit for affidavit of service 590 0.40 236.00 Mairead Dinneen 1//10/2024 Formulating exhibit of 21k pages. Contacted and liaised with IT. 590 2.60 1,573.00 Jhneil Stewart 17/10/2024 Matter management 910 0.20 182.00 Jhneil Stewart 17/10/2024 Considering strategy with AMT re exhibit (0.2); finalizing Despins 4 (cross refs with exhibit and review of same), (1.4) emails to clients re next step

Jhneil Stewart 18/10/2024 Finalizing Despins 3 an 4 for filing (0.8), emails and calls with client, (0.4) compiling and compressing exhibit for filing, (0.4) strategy meeting re next steps (0.4), email to client re strategy for return date hearing,(0.4)

Mairead Dinneen 18/10/2024 Finalising exhibit for filing. 590 1.40 826.00 James Petkovic 18/10/2024 Discussion on Kwok re taking things forward. 1045 0.40 418.00 Isobel McNaught 18/10/2024 Continuation application: Discussion with JQS regarding Despins 4 and collating documents for filing, consideration of correspondence

Marcia McFarlane 18/10/2024 Assisted with filing tasks for injunction continuation application 1300 0.40 520.00 Isobel McNaught 21/10/2024 Sending continuation application to JBP 590 0.20 118.00 James Petkovic 21/10/2024 Working on continuation skeleton and emailing to team. 1045 2.00 2,090.00 James Petkovic 22/10/2024 Considering letter from other side and amending skeleton in the light of

Isobel McNaught 22/10/2024 Draft Letter to Ogier re representative timeline for responsive evidence and historical position. 590 1.20 708.00 Isobel McNaught 22/10/2024 Injunction: Ex parte transcript - serving on Respondents 590 0.40 236.00 Isobel McNaught 22/10/2024 Continuation application: Updating affidavit of service (0.6), preparing hearing bundle (1.0), serving hearing bundle (0.2), liaising with Paul Hastings regarding timelines (0.4), updating skeleton (inc cross-

Isobel McNaught 23/10/2024 Originating application: review of letter to Ogier and liaising with team

lsobel McNaught 23/10/2024 Return date hearing: discussion with team regarding steps in advance 590 0.40 23600 Jhneil Stewart 23/10/2024 Finalize, file and serve skeleton for return date (0.6), numerous emails and hearing prep for return date (0.8). 910 1.40 1,274.00 Jhneil Stewart 23/10/2024 Strategy meetings 910 2.00 1,820.00 Jhneil Stewart 23/10/2024 Email response to Luc re query on injunction 910 0.20 182.00 Jhneil Stewart 23/10/2024 Review skeleton and amends re same 910 0.40 364.00

Jhneil Stewart 23/10/2024 Drafting response letter to Ogier and email re same; attending to AMT's queries and finalizing letter and updating client on next steps 910 2.60 2,366.00

Jhneil Stewart 23/10/2024 Ace decade: Email to AMT re Ace Decade; amends to claim docs and

James Petkovic 23/10/2024 Discussing case in terms of response to originating application, preparing speaking note prep ahead of tomorrow's continuation application. 1045 7.00 7,315.00 Jhneil Stewart 24/10/2024 Ace decade: Emails re evidence for Ace Decade claim and considering

Jhneil Stewart 24/10/2024 Ace decade: Hearing preparation and attending hearing (1.00) ; stat with AMT and considering underlying evidence and drafting evidence for Ace

Jhneil Stewart 24/10/2024 Emails re letter to Ogier and amends re same 910 0.40 364.00 Isobel McNaught 24/10/2024 Continuation: preparation of hard copy documents, consent order,

James Petkovic 24/10/2024 Ace decade: (1) Preparing and attending continuation return date hearing, also negotiating and agreeing draft order with other side before hearing and amending draft order after hearing following discussion at the hearing with the judge (3.5 hours); (2) reviewing ACE Decade Points of Claim (1.5 hours) 1045 5.00 5,075.00 Jhneil Stewart 25/10/2024 Ace decade: Reviewing numerous documents (3.0), drafting evidence and point of claim for Ace Decade (4.0), emails and call with client re

Jhneil Stewart 26/10/2024 Ace decade: Consider documents sent by clients and points for Despins 1 and email to team re next steps: Ace Decade claim 910 0.60 546.00 Marcia McFarlane 28/10/2024 Ace decade: Proof reviewed the first draft of the evidence supporting the claim concerning Ace Decade and Dawn and provided comments. Reviewed draft letter to Ogier re Ace Decade 1300 1.40 1,820.00 André McKenzie 28/10/2024 Emails to/from JBO re hearing on 18 November. 935 0.20 182.00 Jhneil Stewart 28/10/2024 Consider Ogier's letter re extension and proposed next steps to team re same (1.0); Discuss strategy and next steps for K Legacy's claim and drafting response letter (0.8) 910 1.80 1,638.00 Jhneil Stewart 28/10/2024 Ace decade: Further draft of Ace Decade points of claim in view of

Jhneil Stewart 28/10/2024 Ace decade: Consider and review further evidence by client and drafting evidence in support of Ace Decade claim 910 4.00 3,640.00 Jhneil Stewart 28/10/2024 Perfecting order for sealing and filing same, instructions to team re arranging sealing (0.40), instructions to team re transcript request (0.20) 910 0.60 546.00 Jhneil Stewart 28/10/2024 Ace decade: Consider query by Pallas re next steps and drafting proposed strategy for AMT review 910 0.60 546.00 Jhneil Stewart 29/10/2024 Ace decade: Discussing Strategy with AMT re Ace Decade and Emails to

Jhneil Stewart 29/10/2024 Ace decade: Consider and attend to AMT comments on Ace Decade evidence (1.2), numerous emails re same and inserts to affidavit in light of clients' additional information (1.4) 910 2.60 2,366.00 Jhneil Stewart 29/10/2024 Ace decade: Call with AMT re next step for K Legacy and Ace Decade claim; discussion next steps with JBP 910 0.40 364.00 Jhneil Stewart 29/10/2024 Email to team re skeleton argument (K Legacy) 910 0.20 182.00 Jhneil Stewart 29/10/2024 Attending to Ogier Letter and preparing strategy email to client re next

Jhneil Stewart 29/10/2024 Consider strategy proposed by AMT and providing comments re same 910 0.20 182.00 Jhneil Stewart 29/10/2024 Collating docs for exhibit and considering further docs provided by client; instructions to IMC re same 910 2.80 2,548.00 Jhneil Stewart 29/10/2024 Ace decade: Instructions re Company Search for Ace Decade and Dawn

James Petkovic 29/10/2024 Commenting on associate's letter regarding other side's extension of time request on Kwok with a view to the letter being circulated to the

Isobel McNaught 29/10/2024 Obtaining sealed order from ELP 590 0.20 118.00 Isobel McNaught 29/10/2024 Ace decade: Consideration of correspondence with Pallas regarding JLs

Isobel McNaught 29/10/2024 Ace decade: Preparation of exhibit LD‐1 590 2.60 1,534.00 James Petkovic 30/10/2024 Discussing next steps on Kwok with Andy and Jhneil. Reviewing and commenting on letters regarding 12 December listing. 1045 0.60 609.00 Jhneil Stewart 30/10/2024 Emails to AMT re status of injunction against K Legacy 910 0.40 364.00 Jhneil Stewart 30/10/2024 Drafting revised letter to Ogier; email to team re same 910 1.60 1,456.00 Jhneil Stewart 30/10/2024 Ace decade: Reviewing letters from Pallas and making comments; email to team re proposed next steps 910 0.80 728.00 Jhneil Stewart 30/10/2024 Strategy Meeting re next steps for K Legacy claim 910 0.60 546.00 Jhneil Stewart 30/10/2024 Ace decade: Reviewing documents and emails to AMT re queries; Further draft of evidence for Ace Decade claim 910 3.00 2,730.00 Jhneil Stewart 30/10/2024 Ace decade: Instructions to IMC re Bankruptcy Code and Ace Decade claim; consider exhibit doc and attending to IMC queries on exhibit 910 0.20 182.00 Jhneil Stewart 30/10/2024 Ace decade" Instructions re Updated Company Searches 910 0.20 182.00 Jhneil Stewart 31/10/2024 Ace decade: Considering rules and preparing step plan for Ace Decade

Jhneil Stewart 31/10/2024 Finalizing revised to Ogier, email to client re evidence (0.40); ReConsider

authorities and rules, preparing summary of position to client, discussion with AMT and JBP re same and updating client (1.40) 910 2.80 2,548.00 Jhneil Stewart 31/10/2024 Matter management 910 0.20 182.00 Jhneil Stewart 31/10/2024 Ace decade: Consider various points for Despins 1 (Ace Decade Claim) and further draft of evidence 910 2.60 2,366.00 James Petkovic 31/10/2024 Discussing email on Kwok with Jhneil and making amends to email with a view to it being circulated to the client. 1045 0.20 203.00 Isobel McNaught 31/10/2024 Ace decade: Updating exhibit LD‐1 590 0.80 472.00 Isobel McNaught 31/10/2024 Review of letter to Ogier (request for directions) 590 0.40 236.00 Isobel McNaught 31/10/2024 Ace decade: Consideration of whether 590 1.80 1,062.00 Andrew Thorp 31/10/2024 Ace decade: Draft letter to hire re directions and setting out basis of

Andrew Thorp 31/10/2024 Ace decade: Review of draft letters and amends to HSF and Court in English proceedings (0.6) and advising on stay and direction in BVI liquidator action (0.4) 1300 1.00 1,300.00 Jhneil Stewart 01/11/2024 Ace decade: Consider strategy for Ace Decade claim with AMT and JBP (2.00); consider next steps in liquidation, consider authorities and steps taken so far and further draft of evidence (4.60); consider authorities on point and instructions to IMC re same (0.60); instruction to

Isobel McNaught 01/11/2024 Ace decade: Research ‐ submission to the 590 3.80 2,242.00 James Petkovic 01/11/2024 Ace decade: (1) Team discussion of Kwok going forward including in particular affidavit in Ace Decade claim and how to progress it (40 minutes); (2) reviewing affidavit in Ace Decade claim, making amends in tracked changes and sending to associate for circulation to PH (2 hours

Andrew Thorp 01/11/2024 Ace decade: Considering position re statement of affairs and . Strat plan for utilizing JL application for 1300 1.20 1,560.00

Andrew Thorp 01/11/2024 Detailed review and edits of lengthy affidavit 1300 2.00 2,600.00

Andrew Thorp 01/11/2024 Ace decade: Emailing JLs re statement of affairs 1300 0.20 260.00 Jhneil Stewart 04/11/2024 Ace decade: Considering suite of documents sent by client and reviewing together with documents shared earlier (2.00); attending to clients comments on affidavit and considering numerous authorities on points (3.00), call with client re amends to affidavit (1.00); attending to clients instructions o points to be addressed to affidavit and making amends (3.00); drafting proposed response to client on strategy (0.80); Attending to email from maples re costs, email proposed response to AMT, email to client re same (0.40) 910 10.20 9,282.00 Marcia McFarlane 04/11/2024 Ace decade: Re draft affidavit, advised on the 1300 0.40 520.00 Jhneil Stewart 05/11/2024 Ace decade: Email to team next steps re Pallas 910 0.20 182.00 Jhneil Stewart 05/11/2024 Ace decade: Edits to step plan {0.20); email to Pallas re response HSF response to their letters (.20) 910 0.40 364.00 Jhneil Stewart 05/11/2024 Email to Maples re offer (0.20); Emails to AMT re next steps (0.40) 910 0.60 546.00 Jhneil Stewart 05/11/2024 Email to team re proposed email to Campbells; email to Campbells re

Jhneil Stewart 05/11/2024 Reviewing US transcripts and further updates to affidavit and proposed

James Petkovic 06/11/2024 Minor amends to affidavit on Kwok following Jhneil circulating a revised draft in the light of client comments. 1045 0.20 203.00 Isobel McNaught 06/11/2024 Ace Decade: Consideration of correspondence concerning request for Statement of Affairs from Mr Hao 590 0.20 118.00 Isobel McNaught 07/11/2024 Ace decade: List of Members: Consideration of letter from Ogier concerning ownership of shares, directions for trial 590 0.40 236.00 Isobel McNaught 07/11/2024 Ace Decade Claim: Consideration of correspondence with Counsel

Isobel McNaught 07/11/2024 Ace Decade Claim: Consideration of correspondence concerning draft Affidavit of Luc Despins 590 0.20 118.00 Jhneil Stewart 07/11/2024 Ace decade: Consider and attend to email from AMT re next steps (0.40); instructions re ace decade exhibit (0.20); email to James Morgan re JLs position and submissions (0.40); email to client re updated affidavit (0.20); emails to team re settlement with maples (0.40); email to Campbells re call (0.20); call with AMT re next steps (0.20); consider letter from Ogier and proposing email to client and next steps (0.40); attending to email queries from client re Ogier's letter (0.20); calls with client re evidence, reviewing UBS complaint, updating Ace Decade evidence, emails to team and counsel re evidence, sending underlying documents to counsel (2.80); email update to team re next steps for Ace Decade claim (0.20); diarisng deadline to respond to Ogier and discussing next steps with JBP (0.40) 910 6.00 5,460.00 Jhneil Stewart 07/11/2024 Ace decade: Consider case law on jurisdiction (0.20) ; email to client re section 245 (0.20) ; instructions to IMC re submission points (Ace Decade

Andrew Thorp 07/11/2024 Advice to PH te 1300 0.60 780.00 Andrew Thorp 07/11/2024 Ace decade: Detailed redraft of affidavit for counsel, synching with US

evidence from US proceedings and default issues. 1300 3.60 4,680.00 Marcia McFarlane 08/11/2024 Reviewed cover letter enclosing Maples cheque on disclosure application; provided comments to letter from Ogier regarding the Trustee's claim served on it 1300 0.40 520.00 Isobel McNaught 08/11/2024 Ace decade: Further research: submission to the 590 0.60 354.00

Jhneil Stewart 08/11/2024 Letter to Maples re settlement and instructions to team re same (0.40); Considering CPR rules and numerous authorities to address points raised by Ogier (2.00); Drafting response letter to Ogier (3.20); discussing points with PAF (0.40); considering strategy and attending to next steps for hearing (0.60) 910 6.60 6,006.00

Jhneil Stewart 11/11/2024 Email to team re next steps for hearing (0.20); instructions to IMC re hearing bundle (0.20); Stat meeting, making amend to letter to Ogier and considering case law (1.60); consider and email to IMC re authorities and note to client (2.60); call with IMC re call with clients and next steps (0.20); email to IMC re proposed email to client (0.20); emails to team attending to clients queries (0.40); calls with JBP and IMC re client's further queries, emails t o team and client re same

James Petkovic 11/11/2024 Beginning to draft skeleton for hearing on 18 November. Arranging alternative advocate in case I was unable to do hearing. 1045 2.40 2,436.00 James Petkovic 11/11/2024 Drafting amendments to letter on Kwok, discussing Kwok with letter with team, instructing associates how to respond to client queries following circulation of letter. 1045 2.40 2,436.00 Isobel McNaught 11/11/2024 Ace decade: Consideration of submission to the 590 0.60 354.00 Isobel McNaught 11/11/2024 Proceedings against Mileson: Discussion with team about draft directions (truncated) and hearing on 18 November 590 0.40 236.00 Jhneil Stewart 12/11/2024 Ace decade: Strategy call with team re clients queries and Ogier letter, email to client and team re same (1.00); email re receipted letter to Maples (0.20); email update to client on draft affidavit for Ace Decade's claim (0.20); considering authorities for skeleton arguments and email to team re proper principle (1.80); considering next steps with JBP (0.60); attending to emails from James Morgan and email to James re clients queries, legal principles and next steps(1.20) 910 5.00 4,550.00 Marcia McFarlane 12/11/2024 C Bankrupt and Net‐ considered with JQS issues of 1300 0.60 780.00 James Petkovic 12/11/2024 Continuing to draft skeleton for hearing on 18 November and circulating

James Petkovic 12/11/2024 Discussion of letter 1045 0.40 406.00 James Petkovic 13/11/2024 Reviewing associates amends to skeleton and preparing covering email to send to client. Also liaising with Court re attempting to block other side's remote hearing request. 1045 1.20 1,218.00 Marcia McFarlane 13/11/2024 Ace Decade claim‐ Considered with JQS the submissions addressing the directions to be agreed by the court to support the trial of the claim 1300 0.20 260.00 Jhneil Stewart 13/11/2024 Reviewing underlying documents and attending to numerous queries by James Morgan (3.00); reviewing hearing bundle index and emails re same; email to clients re docs requested by James (0.20);email to AMT re client queries (0.20);reviewing draft skeleton and further draft of same (2.80); email to AMT re update to client re Maples costs; attending to email from Ogier to court and update to AMT (0.40: email to JBP re next steps (0.20); email to court re Ogier remote hearing request (0.20); considering next steps and updating action list(0.40); instructions to IMC re diarising deadline (0.20) 910 7.60 6,916.00 Isobel McNaught 13/11/2024 Originating application (Mileson): Preparation of hearing bundle for hearing on 18 November 2024 590 1.60 944.00

Andrew Thorp 14/11/2024 Ace decade: Conference with James Morgan re strategy, pleadings and

James Petkovic 14/11/2024 Amending skeleton in the light of letter from other side and amends from client throughout the day. 1045 2.00 2,030.00 Isobel McNaught 14/11/2024 18 November hearing: Liaising with Mrs Chambers regarding listing of hearing (whether before Justice Mithani or Wallbank) ‐ attempted telephone call and email 590 0.20 118.00 Jhneil Stewart 14/11/2024 Ace decade: Numerous emails with clients and team re hearing strategy, prep and finalizing directions skeleton (2.20); consider and attend to letter from Ogier (0.40); drafting proposed response to Ogier (0.20); consider and attend to emails from James M and AMT re Ace Decade's claim (0.40); finalsing steps plan to Pallas and email to team re same (0.40); considering evidence for hearing (0.40); attend to query from PAF (0.20); instructions to IMC re next steps and hearing prep (0.20) 910 4.40 4,004.00 Jhneil Stewart 15/11/2024 Dawn state: Attend to email from client re update to skeleton, numerous emails to IMC re skeleton and refs, instructions to team re authorities bundle and hearing bundle, reviewing skeleton and instructions to IMC re next steps, team call with PAF re hearing prep, email update to client re filings, considering respondents skeleton arguments and updating team on inaccuracies, call with JBP re considerations for hearing and email to court re hard copy bundles, email to team re listing (3.60), considering cases to attend to client's query on BVI insolvency rules on avoidance actions (2.00); attend to emails from James Morgan re Ace Decade (0.60); consider position from Campbells re docs in liquidation (0.20); consider letters from Pallas on JLs position and next steps (0.20); considering next steps and circulating update to team (0.20); consider cases to attend to James M queries re recognition (0.60); circulating dial‐n for meeting (0.20); call with JBP and email with AMT re proposed call with James M (0.20) 910 7.80 7,098.00 James Petkovic 15/11/2024 Call with PAF, IM, JQS re directions hearing on Monday to discuss the position we are adopting. 1045 0.40 406.00 Isobel McNaught 15/11/2024 Preparation for hearing on 18 November (hard copies) 590 0.20 118.00 Isobel McNaught 15/11/2024 Cross referencing skeleton argument 590 2.00 1,180.00 Isobel McNaught 15/11/2024 Call with PAF, JQS and JBP regarding hearing on 18 November 590 0.60 354.00 Isobel McNaught 18/11/2024 Updates to procedural chronology and filing 590 0.40 236.00 Isobel McNaught 18/11/2024 Discussion 590 0.40 236.00 Isobel McNaught 18/11/2024 Draft order from hearing on 18 November 2024: Liaising with JQS regarding terms of draft order 590 0.20 118.00 Isobel McNaught 18/11/2024 Originating application: Updating hearing note and diarising deadlines

Isobel McNaught 18/11/2024 Preparation for originating application hearing (consideration of Insolvency Rules and liaising with PAF regarding) 590 0.60 354.00 Isobel McNaught 18/11/2024 Attending hearing (originating application / direction) 590 1.20 708.00 Peter Ferrer 18/11/2024 Preparing for and attending court 1300 5.80 7,540.00 James Petkovic 18/11/2024 Attending meetings prior to hearing to discuss strategy and approach(1.0) . Attending hearing(0.4). Reviewing associate's summary email to client and draft order and providing amendments (0.4). 1045 2.60 2,639.00 Jhneil Stewart 18/11/2024 Ace decade: Update to client on JLs position re requested documents 910 0.20 182.00 Jhneil Stewart 18/11/2024 Ace decade: Considering next steps with AMT re Ace Decade claim (0.40), considering and attending to emails from James M (0.40); brief review of pleadings (0.40), arranging call with James M (0.20) 910 1.40 1,274.00

Jhneil Stewart 18/11/2024 Hearing prep: strategy meeting with PAF, AMT and Team (1.0), drafting and arranging filing of procedural chronology (0.8), emails to IMC re next steps, conference with PAF re proposed WPSATC call with Ogier (1.2), WPSATC call with Ogier, considering IA rules and application of CPR (0.2), calls with court re available dates for a listing, email to IMC re draft email to court, emails to team re court's position, reviewing bundles and skeleton and making points for hearing (0.5), hearing attendance, post hearing attendances :catch up with AMT and PAF, drafting draft order and email update to client, reviewing hearing note from IMC, instructions to IMC re diarising deadlines, requesting hearing transcript, emails to team re next steps. (3.0) 910 9.00 8,190.00

Jhneil Stewart 19/11/2024 Reviewing POC (Ace Decade), comments to James M, considering evidence and emails to James re next steps and underlying evidence(3.20); considering and preparing call agenda, email to James M re same (0.40); emails to client re proposed call (0.20); instructions to IMC re next steps for exhibit (0.20 910 3.80 3,458.00 Jhneil Stewart 19/11/2024 Consider and attend to email from Ogier on draft order (0.20); emails with AMT and PAF re clients queries (0.20); considering next steps and instructions to IMC re same 910 0.60 546.00 Jhneil Stewart 19/11/2024 Strategy call with James M and post call attendances (0.2); considering evidence and instructions to IMC (0.4), call with JBP re next steps and email to James M re same (0.8) 910 1.40 1,274.00 Jhneil Stewart 19/11/2024 Ace decade: Consider and attend to email from Ogier re dates to avoid 910 0.20 182.00 James Petkovic 19/11/2024 Ace decade: (1) revising steps plan on ACE Decade and emailing to associate (1.0); (2) prepping for and attending call with Counsel re taking ACE Decade claim forward(1.0) ; (3) liaising with Counsel's clerk regarding listing; (4) reviewing ACE Decade draft PoC and proposing

Andrew Thorp 19/11/2024 Ace decade: Emails in and out re listing and professional position of

Jhneil Stewart 19/11/2024 Email update to client and counsel (0.40), email to Ogier re draft order (0.20), considering next steps: instructions to IMC re James M dates to avoid (0.20); emails to IMC re listing and next steps (0.20); follow up email to Ogier re dates to avoid (0.20) 910 1.20 1,092.00 Jhneil Stewart 19/11/2024 Emails to team. James M and client re strategy call 910 0.20 182.00 Jhneil Stewart 19/11/2024 RE Ace decade: Email to JBP re POC (Ace Decade) 910 0.20 182.00 Jhneil Stewart 19/11/2024 Consider and attend to JBP email re step plan to Pallas 910 0.20 182.00 Isobel McNaught 19/11/2024 Ace decade: Call with James Morgan KC re points of claim (0.2), whether

Isobel McNaught 19/11/2024 Listing of trial and CMC: Liaising with team and counsel's clerks regarding

Isobel McNaught 20/11/2024 PTR and trial listing: liaising with Counsel's clerk and updating Listing

Isobel McNaught 20/11/2024 Sending order for sealing 590 0.20 118.00 Isobel McNaught 20/11/2024 Drafting letter to Ogier re sale of apartment 590 0.60 354.00 Jhneil Stewart 20/11/2024 Considering rules and darting table of deadlines (1.60); reviewing and amending draft letter to Ogier re variation of injunction 910 2.00 1,820.00 Jhneil Stewart 20/11/2024 Reviewing underlying material, considering CPR rules and preparing detailed strategy for trial and next steps (3.00): emails re listing of trial (0.20); instructions to IMC re arranging sealed order (0.20) 910 3.40 3,094.00

Jhneil Stewart 20/11/2024 Con with JBP re next steps for client strategy meeting, emails to client and counsel re next steps 910 0.40 364.00

Jhneil Stewart 20/11/2024 Ace decade: Reviewing POC and circulating comments (0.6), updated to supporting evidence and discussing same with JBP (0.8) 910 1.40 1,274.00 Jhneil Stewart 20/11/2024 Ace decad: Email to AMT re next steps and proposed call with Pallas 910 0.20 182.00 Andrew Thorp 20/11/2024 Draft strategy note on BVI proceedings and position of Milesons lawyers re listing (0.4), providing directions and advice on evidence and

James Petkovic 20/11/2024 Ace decade: (1) Drafting and amending covering email and note from James Morgan KC regarding note to send out (0.5); (2) reviewing and making further changes to Ace Decade Points of Claim (0.5); (3) liaising with other side re their alleged unavailability for trial on Ace Decade claim and also liaising with our Counsel's clerks re his availability (0.2); (4) reviewing and amending draft letter re offer to the other side of varying injunction to enable property to be sold. (0.8) 1045 2.00 2,030.00 Jhneil Stewart 21/11/2024 Instructions to IMC re status of companies (0.20); emails to team and counsel re meeting and prep for client meeting (0.40), pre call with counsel, call with client team and counsel, post client meeting discussion with Counsel and Harenys, considering and attending to steps for pre‐ trial hearing and trial prep (3.20) 910 3.80 3,458.00 Jhneil Stewart 21/11/2024 Preparing note on disclosure duties and preparing covering email to clients re strategy and step plan; preparing draft WS and List of Documents to be sent to client (3.00); discussing next steps for letter to

Jhneil Stewart 21/11/2024 Ace decade: Call with client re Ace Decade transfer, email to client re

James Petkovic 21/11/2024 Preparing for and attending call with client (0.4); Discussing with Counsel and team how to progress case both before and after call with client (1.0)t; liaising with other side and Counsel's clerks regarding listing dispute both before and after (0.8) (4) reviewing amended PoC and sending on to client. (0.4) 1045 2.60 2,639.00 Andrew Thorp 21/11/2024 Ace decade: Review of statement of claim and edits: commentary for Ace Decade application 1300 2.40 3,120.00 Andrew Thorp 21/11/2024 Con with OH re position and strategy 1300 1.80 2,340.00 Andrew Thorp 21/11/2024 Ace decade: Considering JLs position upon review of case law and stay position in English proceedings 1300 1.00 1,300.00 James Petkovic 22/11/2024 Reviewing and amending associate's drafts of: (1) draft email to client regarding next steps on K Legacy and ACE Decade claim (0.4); (2) disclosure obligations letter on K‐Legacy claim and witness statement and exhibit templates on K‐Legacy (0.8); (3) valuer mechanism letter, and further amends following client comments on K Legacy claim (0.4); (4) draft affidavit evidence of Luc Despins in ACE Decade claim (0.8); amending steps plan in ACE Decade claim (0.4) (5) liaising with associate regarding tasks in course of day on both ACE Decade and Kwok claims

Jhneil Stewart 22/11/2024 Discussion with AD re billing 0 0.20 ‐ Jhneil Stewart 22/11/2024 Considering and updating list of next steps 910 0.20 182.00 Jhneil Stewart 22/11/2024 Ace decade: Considering letters from Pallas with AMT and next steps 910 0.40 364.00 Jhneil Stewart 22/11/2024 Circulating next steps for listing request 910 0.20 182.00 Jhneil Stewart 22/11/2024 Ace decade: Updates to Step Plan to deal with new strategy re (0.6); Considering CPR rules (0.3), discussion with JBP re same and email to James M (0.3) 910 1.20 1,092.00 Jhneil Stewart 22/11/2024 Ace decade: Consider and make amends to Despins 1, email to James M

Jhneil Stewart 22/11/2024 Ace decade: Emails re Proposed call with Pallas; circulating diary invite 910 0.40 364.00

Jhneil Stewart 22/11/2024 Ace decade: Consider email from James re effect of JLs appointment and case law re same; discussing with AMT (0.4); reviewing file and circulating fee points to AMT (0.6) 910 1.40 1,274.00 Jhneil Stewart 22/11/2024 Consider and attend to client suggested amends for draft letter to Ogier, discussing same with AMT and JBP, email to client re revised draft 910 0.40 364.00 Jhneil Stewart 22/11/2024 Dawn state: Updating letter to Ogier to address mechanism for sale (0.40), updated to suite drafts docs in support of claim, covering email and disclosure note to clients (1.60); discussing next steps with JBP and email to clients re same (0.40) 910 2.40 2,184.00 James Petkovic 26/11/2024 Ace decade: Call regarding Pallas requests and discussion with Jhneil re tasks following call with Pallas. 1045 0.40 406.00 Isobel McNaught 26/11/2024 Ace decade: Discussion with Harneys team in advance of call with Pallas 590 0.20 118.00 Isobel McNaught 26/11/2024 Listing Request Form 590 0.60 354.00 Jhneil Stewart 26/11/2024 Instructions re BVI cases 910 0.20 182.00 Jhneil Stewart 26/11/2024 Consider and attend to email from client re similar fact evidence 910 0.40 364.00 Jhneil Stewart 26/11/2024 Ace decade: Emails re JLs directions hearing 910 0.60 546.00 Jhneil Stewart 26/11/2024 Meeting with IMC re next steps 910 0.20 182.00 Jhneil Stewart 26/11/2024 Ace decade: Consider client email re Yvette Wang's evidence and instruction to IMC re next steps 910 0.40 364.00 Jhneil Stewart 26/11/2024 Ace decade: Attend to email from Pallas re proposed meeting 910 0.20 182.00 Jhneil Stewart 26/11/2024 Ace decade: Attend to tasks following call with Pallas (0.2); email to Pallas re next steps (0.2) 910 0.40 364.00 Jhneil Stewart 26/11/2024 Ace decade: Consider counsel amends to Strategy Plan (0.2); preparing meeting agenda for call with Pallas (0.2) 910 0.40 364.00 Isobel McNaught 26/11/2024 Discussion with JQS regarding actions 590 0.40 236.00 Isobel McNaught 26/11/2024 Ace Decade Claim: collating documents for exhibit 590 0.20 118.00 Andrew Thorp 26/11/2024 Ace decade: Considering JLs position re disclosure and undertaking (0.2), legal position tr privilege and confidentiality of filed documents(0.2) 1300 0.40 520.00 Andrew Thorp 26/11/2024 Ace decade: Call with Pallas re stay and UBS position 1300 0.20 260.00 Marcia McFarlane 26/11/2024 Considered advice on 1300 0.60 780.00 Jhneil Stewart 26/11/2024 Consider and attend to disclosure query from Pallas (1.0); considering cases and providing summary on the collateral use of documents (3.2) 910 4.20 3,822.00 Jhneil Stewart 26/11/2024 Consider authority on 910 0.40 364.00 Jhneil Stewart 26/11/2024 Considering authorities on 910 0.60 546.00 Jhneil Stewart 27/11/2024 Reviewing documents from client re

providing summary update to team 910 1.80 1,638.00 Jhneil Stewart 27/11/2024 Ace decade: Consider email from JBP re disclosure request from UBS (0.20); consider email and next steps re listing and discussing next steps

Jhneil Stewart 27/11/2024 Ace decade: Instructions re 910 0.20 182.00 Jhneil Stewart 27/11/2024 Ace decade: Correspondence re proposed call with Campbells 910 0.20 182.00 Isobel McNaught 27/11/2024 PTR and trial listing: Liaising with JBP regarding listing of PTR (0.4), consideration of approach in light of disagreement on available dates(0.6), updating Listing Request Form (0.2) 590 1.20 708.00

James Petkovic 27/11/2024 Dawn state: Reviewing associates research re collateral use queries re Pallas request and writing email to partner re proposed way forward (0.4); amending listing request form and email to other side re listing for trial ‐ liaising with partner and associate in this regard and having email sent to other side (0.8). 1045 1.20 1,254.00

James Petkovic 28/11/2024 Ace decade: Discussing approach re UBS request for documents with partner (0.2), writing to Pallas to inform them we had requested information from JLs lawyer and would update them when we heard

Jhneil Stewart 28/11/2024 Ace decade: Consider proposed email to Pallas re UBS 910 0.20 182.00 Jhneil Stewart 28/11/2024 Ace decade: Email to James M re evidence 910 0.40 364.00 Jhneil Stewart 28/11/2024 Instructions to IMC re email to James M re filed documents 910 0.20 182.00 Jhneil Stewart 28/11/2024 Considering further cases on the applicability of foreign law 910 1.80 1,638.00 Jhneil Stewart 28/11/2024 Considering next steps with AMT 910 0.20 182.00 Jhneil Stewart 28/11/2024 Ace decade: Considering next steps re disclosure to UBS with JBP, update on futile calls to Campbells (0.20); discussing foreign law point

Andrew Thorp 28/11/2024 Ace decade: Fresh revision of points of claim re ace decade and timetabling of disposal and steps plan 1300 1.20 1,560.00 Andrew Thorp 29/11/2024 Ace decade: Mail to Campbells rr disclosure provisions of sanction

Andrew Thorp 29/11/2024 Ace decade: Advising on listing position and listing request form 1300 0.40 520.00 Jhneil Stewart 29/11/2024 Ace decade: Consider email from JBP re next steps and drafting proposed email to Pallas and Campbells re request (0.4); consider email from JBP and email to Pallas and Campbells re same (0.4) 910 0.80 728.00 Jhneil Stewart 29/11/2024 Ace decade: Call with Campbells re UBS disclosure request (0.20); email to team re next steps and drafting revised email to client in view of the JLs position (0.40); cal with JBP re next steps and email re same (0.40) 910 1.00 910.00 James Petkovic 29/11/2024 Drafting email to the Court regarding listing dispute on Kwok and sending up to partner for review. 1045 0.40 418.00

Jhneil Stewart 02/12/2024 Email to team re letter to Ogier 910 0.20 182.00

Jhneil Stewart 02/12/2024 Ace decade: Email to Campbells on UBS disclosure request 910 0.20 182.00 Jhneil Stewart 02/12/2024 Ace decade: Email to James M re client's position on POC and memo

Jhneil Stewart 02/12/2024 Ace decade: Considering several cases on 910 2.40 2,184.00 Jhneil Stewart 02/12/2024 Dawn state: Call with IMC re next steps for K Legacy (0.20); consider and respond to query from James M re PoC (0.20); email to clients re

Isobel McNaught 02/12/2024 PTR and trial Finalising and filing listing request form 590 0.40 236.00 Isobel McNaught 03/12/2024 Trial: Review of defendants' listing request form and sending to team 590 0.20 118.00 Jhneil Stewart 03/12/2024 Ace decade: Email to James re memo and next steps 910 0.40 364.00 Jhneil Stewart 03/12/2024 Considering next steps with JBP and email to clients re letter to Ogier (0.40: finalising letter and sending email to Ogier and updating client

Jhneil Stewart 03/12/2024 Considering further authorities on 910 0.80 728.00 Jhneil Stewart 03/12/2024 Consider 910 0.20 182.00 Jhneil Stewart 03/12/2024 Ace decade: Email to James re client memo on

client re revised POC, further email to James M re next steps and

Jhneil Stewart 03/12/2024 Ace decade: Email to Pallas re disclosure to UBS; uploading docs to

Isobel McNaught 04/12/2024 Meeting regarding action list and next steps 590 1.60 944.00 James Petkovic 04/12/2024 Team meeting on Kwok to discuss tasks going forward. 1045 0.40 418.00 Jhneil Stewart 04/12/2024 Comprehensive email to AMN on procedural next steps and working

Jhneil Stewart 04/12/2024 Comprehensive review of file to address

drafting response to client 910 1.80 1,638.00 Marcia McFarlane 04/12/2024 Considered 1300 0.20 260.00 Jhneil Stewart 04/12/2024 Considering disclosure next steps with AMN and proposed call with

Jhneil Stewart 04/12/2024 Ace decade: Stat Meeting with AMT re next steps and subsequent team meeting to discuss various work steams and next steps 910 2.20 2,002.00 Jhneil Stewart 04/12/2024 Considering strategy re video evidence and correspondences of approach taken by Court 910 0.40 364.00 Aurelia Matonis 05/12/2024 Looking up cases and citations 590 0.80 484.00 Aurelia Matonis 05/12/2024 Reviewing authorities 590 1.20 726.00 Aurelia Matonis 05/12/2024 Reviewing documents and preparing chronology 590 5.20

cited in USS pleading and amending. Considering g further authorities and next steps. 1300 3.00 3,900.00 Andrew Thorp 05/12/2024 Ace decade: Advice regarding 1300 0.40 520.00 Jhneil Stewart 05/12/2024 Ace decade: Email to client re strategy for validity 910 0.20 182.00 Jhneil Stewart 05/12/2024 Ace decade: Email to JBP re draft email to James M on 910 0.40 364.00 Jhneil Stewart 05/12/2024 Ace decade: Email to team re JLs advice re 910 0.20 182.00 Jhneil Stewart 05/12/2024 Considering authorities on video link evidence and email to team re

Jhneil Stewart 05/12/2024 Ace decade: Emails and calls with JBP re next steps for JLs directions application; arranging hearing prep, finalisation of skeleton and

Jhneil Stewart 05/12/2024 Ace decade: Consider email from JBP re proposed email update to

hearing and putting them on notice of costs 910 0.40 364.00 Jhneil Stewart 05/12/2024 Ace decade: Stat meeting re proposed points to be made by trustee at JLs directions hearing 910 0.60 546.00 Jhneil Stewart 05/12/2024 Ace decade: Discussing next steps and email to James M re revised

James Petkovic 05/12/2024 Ace decade: Considering James Morgan KC's advice re approach to hearing on 12 December. Reading case cited and drawing up email to client. Making amends following partner comments and having email

Jhneil Stewart 05/12/2024 Ace decade: Email to Pallas re copy of order extending the stay 910 0.20 182.00 Jhneil Stewart 06/12/2024 Considering query re 910 0.40 364.00 James Petkovic 06/12/2024 Ace decade: Reviewing Jhneil's email to James Morgan KC. Making minor amendments and having sent out. 1045 0.40 418.00 Jhneil Stewart 06/12/2024 Email to James M on foreign law 910 0.20 182.00 Jhneil Stewart 06/12/2024 Considering action list and updating next steps 910 0.60 546.00

Jhneil Stewart 06/12/2024 Discussion with AMN re next steps and disclosure 910 0.40 364.00

Aurelia Matonis 06/12/2024 Discussion with JS re e‐disclosure and call with the client 590 0.80 484.00 Natalie Lee 06/12/2024 Reviewing and commenting on submissions. 1015 2.40 2,436.00 Natalie Lee 09/12/2024 Considering pleadings. 1015 1.40 1,421.00 James Petkovic 09/12/2024 Dawn State: (1) considering ways forward re disclosure, drawing up draft email to client and having it sent out; (2) reviewing amendments

Aurelia Matonis 09/12/2024 Reviewing email from JS re 590 0.20 121.00 Aurelia Matonis 09/12/2024 Draft email to client re disclosure 590 0.40 242.00 Aurelia Matonis 09/12/2024 Ace decade: Emails in from JQS and JBP re next steps and draft POC 590 0.20 121.00 Aurelia Matonis 09/12/2024 Ace decade: Email in from James Morgan KC re draft POC and

Aurelia Matonis 09/12/2024 Discussion with JBP 590 0.20 121.00 James Petkovic 09/12/2024 Beginning to read into hearing bundles for JL's application. 1045 0.80 836.00 Jhneil Stewart 09/12/2024 Review proposed email to client on disclosure and considering next

Jhneil Stewart 09/12/2024 Ace decade: Email to James M re affidavit and next steps 910 0.20 182.00 Jhneil Stewart 09/12/2024 Ace decade: Amends to affidavit in light of revised PoC and 910 2.00 1,820.00 Jhneil Stewart 09/12/2024 Email to JBP re proposed disclosure agenda and call, emails to team

Jhneil Stewart 09/12/2024 Ace decade: Review PoC and consider authority and make amends, progressing draft PoC 910 1.40 1,274.00 Jhneil Stewart 09/12/2024 Email to JBP re instructions to consider amending K Legacy PoC 910 0.20 182.00 Jhneil Stewart 10/12/2024 Consider emails and circulating dial in re disclosure call 910 0.20 182.00 Jhneil Stewart 10/12/2024 Email to JBP re Counsel query on affidavit 910 0.20 182.00 Jhneil Stewart 10/12/2024 Ace decade: Consider and attend to clients amends to POC and further draft of supporting evidence, emails to client and JBP re same; consider and attend to JBP amends, email to James Morgan re same and next

James Petkovic 10/12/2024 Ace decade: (1) reading into hearing bundles for hearing on 18 December (2.0); reviewing and amending associate's amendments to PoC and affidavit on Ace Decade and instructing them to be sent on to James Morgan KC (1.0) 1045 3.00 3,135.00 Aurelia Matonis 10/12/2024 Ace decade: Email in from AB at Paul Hastings re POC 605 0.20 121.00 Aurelia Matonis 11/12/2024 Reviewing email to client re disclosure next steps 605 0.20 121.00 Aurelia Matonis 11/12/2024 Meeting with Paul Hastings re Disclosure and discussion with team re

James Petkovic 11/12/2024 Preparing for and attending disclosure meeting and co‐ordinating next steps with team after meeting. 1045 1.00 1,045.00 James Petkovic 11/12/2024 Ace decade: Beginning to work on oral submissions for hearing on 18

James Petkovic 11/12/2024 There was further time preparing for the hearing today but I am marking it as non‐billable to keep costs down. 0 1.00 ‐

Jhneil Stewart 11/12/2024 Ace Decade: Email to IMC re memo on and exhibit (0.20); considering rules and next steps for K Legacy (0.60); email to ANM re next steps, transcripts, listing and other matters (0.40); email to team re Ace Decade PoC and reviewing James comments (0.40); email to team re status of K wok entities (0.20); instructions to team re uploading correspondences and documents to be shared with James

Jhneil Stewart 11/12/2024 Call with PH re disclosure, post catch up call and considering strategy, discussing same with AMT, considering recommended e-disclosure providers, drafting email update to clients re next steps 910 2.80 2,548.00 Jhneil Stewart 11/12/2024 Emails with James Morgan re next steps and K Legacy PoC, sharing all filed document with James (0.40) 910 0.40 364.00 Jhneil Stewart 12/12/2024 Ace Deacde: Addressing James M comments in draft affidavit, email to team re same , discussing with James M 910 2.20 2,002.00 Jhneil Stewart 12/12/2024 Reviewing underlying documents and considering and preparing draft list of search terms and table of categories of documents (4.0), search terms and date ranges, team meeting re disclosure (1.0),Witness statements and next steps for trial (1.0) 910 6.00 5,460.00 Jhneil Stewart 12/12/2024 Email re next steps for proposed meeting, updating list of next steps in

James Petkovic 12/12/2024 Attending disclosure meeting with team to discuss next steps on disclosure going forward. 1045 1.00 1,045.00 James Petkovic 12/12/2024 Ace decade: Completing first draft of speaking note for hearing on 18 December and emailing to team. 1045 5.00 5,225.00 Aurelia Matonis 12/12/2024 Email from JQS re transcripts and listing the PTR and trial 590 0.80 484.00 Isobel McNaught 12/12/2024 Ace decade: Updating exhibit LD-1 (reorganising documents, review of affidavit, identifying new documentation and liaising with JBP) 590 4.40 2,596.00 Andrew Thorp 12/12/2024 Review of points of claim and commentary 1300 1.60 2,080.00 Andrew Thorp 12/12/2024 Ace decade: Considering 1300 0.60 780.00 Andrew Thorp 12/12/2024 Considering disclosure terms and strategy, instructing team and draft directions for court and trial 1300 1.20 1,560.00 Aurelia Matonis 13/12/2024 Ace decade: Reviewing skeleton arguments for hearings next week - joint liquidators directions application 590 0.60 363.00 Jhneil Stewart 13/12/2024 Ace decade: Reviewing JBP speaking notes and making comments, circulating orders for court re same 910 1.00 910.00 Jhneil Stewart 13/12/2024 Ace Decade: further amends to affidavit and comments to POC (0.80); considering next steps and updating task list (0.40); discussing next steps with AMT and vesting point, email to client re same (0.40) 910 1.60 1,456.00 Jhneil Stewart 16/12/2024 Considering client query re compelling witness and email to team re

Jhneil Stewart 16/12/2024 Sending emails to James M re strategy for K Legacy PoC, next steps and chaser to court on trial date 910 0.60 546.00 Jhneil Stewart 16/12/2024 Attend to client query re disclosure and instructions to team re same 910 0.40 364.00 Aurelia Matonis 16/12/2024 Calling court registry re listing of PTR and trial 590 0.20 121.00 Aurelia Matonis 16/12/2024 Drafting email to client re link to the exhibit bundles 590 0.20 121.00 Aurelia Matonis 16/12/2024 Email out to client re link to the exhibits 590 0.20 121.00 Aurelia Matonis 17/12/2024 Reviewing disclosure search terms 590 0.40 242.00

Jhneil Stewart 17/12/2024 Considering underlying evidence and working on list of proposed search terms, several emails to JBP and ANM re disclosure 910 4.20 3,822.00

Jhneil Stewart 17/12/2024 Email to AMT re stay of English proceedings 910 0.20 182.00 Jhneil Stewart 17/12/2024 Ace decade: Collating docs for Ace Decade exhibit, consider clients email on evidence and emails to client and James Morgan re proposed

Jhneil Stewart 17/12/2024 Ace decade: Consider clients comments on Ace Decade drafts an email

Jhneil Stewart 17/12/2024 Consider update from court on listing (0.20); consider email from JBP re disclosure (0.20); consider next steps for disclosure (0.20) 910 0.60 546.00 Jhneil Stewart 17/12/2024 Email to client re letter to Ogier 910 0.20 182.00 Marcia McFarlane 17/12/2024 Advise on the issue of whether a letter of request application can be

James Petkovic 17/12/2024 Reviewing list of disclosure terms from Jhneil and providing comments

James Petkovic 17/12/2024 Ace decade: Preparing for hearing tomorrow. 1045 1.80 1,881.00 Andrew Thorp 17/12/2024 Strategy briefing for counsel and advocacy notes for court. 1300 1.20 1,560.00 James Petkovic 18/12/2024 Updating team on hearing post‐hearing and discussing implications of hearing with team, drafting up draft order from the hearing. 1045 1.20 1,254.00 James Petkovic 18/12/2024 Ace decade: Attending hearing on joint liquidator's application. 1045 1.20 1,254.00 James Petkovic 18/12/2024 Ace decade: Preparing for hearing on Kwok ‐ review of file pre‐hearing, running through and amending speaking notes, discussing case and our position with Andy Thorpe pre‐hearing, calling to Joint Liquidators' pre‐ hearing to discuss our position. 1045 2.00 2,090.00 Jhneil Stewart 18/12/2024 Consider AMT proposed advise on clients disclosure query 910 0.20 182.00 Jhneil Stewart 18/12/2024 Ace decade: Making amends to Ace Decade affidavit and POC, emails to James Morgan re same, reviewing draft memo on

drafting OA, significant review of underlying docs for exhibit and instructions to ANM re exhibit (5:40) and next steps, email to AMT final docs, attending JLs directions hearing, post hearing call and discussing next steps, updating trustee and James on hearing outcome and attending to clients queries (9.00) 910 9.40 8,554.00 Aurelia Matonis 18/12/2024 Email out to JQS re disclosure 590 0.20 121.00 Aurelia Matonis 18/12/2024 Ace decade: Preparing exhibit LD1 re ACE Decade 590 0.20 121.00 Aurelia Matonis 18/12/2024 Amending attendance note from hearing on 18 December 2024 590 0.40 242.00 Andrew Thorp 18/12/2024 Considering directions order and amending for sealing by the court 1300 0.40 520.00 Andrew Thorp 18/12/2024 Call with Campbells pre hearing rr strategy and submissions 1300 0.40 520.00 Andrew Thorp 18/12/2024 Considering JLs submissions and instructions for strategy and Judges

Andrew Thorp 18/12/2024 Draft letter to Milesons lawyers re disclosure parameters and detailed consideration of search terms 1300 1.20 1,560.00 Andrew Thorp 18/12/2024 Drafting note of hearing for PH 1300 0.20 260.00 Aurelia Matonis 19/12/2024 Research re 590 1.20 708.00 Aurelia Matonis 19/12/2024 research re 590 0.60 354.00 Aurelia Matonis 19/12/2024 Team catch up re action list 590 2.00 1,210.00

Jhneil Stewart 19/12/2024 Ace decade: Email to IMC on memo on 910 0.20 182.00

Jhneil Stewart 19/12/2024 Reviewing file and updating on service of JLs application on Hao 910 0.40 364.00 Jhneil Stewart 19/12/2024 Ace decade: Team call re strategy for K Legacy and Ace Decade liquidation (2:00, email to James M re next steps for Ace Decade and US memo (0.40); formatting memo and emails to AMT and JBP re US law memo (0.60); considering numerous authorities on hearsay and WS sending numerous emails on advise note (3.00); drafting advise note on disclosure (2.60); email update to Pallas on hearing (0.20); email to client on disclosure search terms (0.20) 910 9.00 8,190.00 James Petkovic 19/12/2024 Dawn state: (1) Attending team meeting regarding tasks going forward on Ace Decade and Dawn State (1 hour 20 minutes); (2) amending and sending draft order from JL's application yesterday on Ace Decade to other side (15 minutes); (3) conducting brief research into point as to whether we could rely on witness statement without calling witness (K Legacy) and emailing team re position in England (15 minutes); (4) conducting research into how to obtain declaratory relief regarding void ab initio point in Ace Decade proceedings (1 hour 30 minutes) 1045 3.20 3,344.00

hours). Review of case law in support of depositions and next steps (1.9

Andrew Thorp 19/12/2024 Call with Alex B re disclosure and directions for Ace Decade 1300 0.40 520.00

, completing opinion for the trustee on stages and strategy. 1300 2.20 2,860.00 Aurelia Matonis 20/12/2024 Research re 590 1.20 708.00 Jhneil Stewart 20/12/2024 Email re status sealed order 910 0.20 182.00 Jhneil Stewart 20/12/2024 K Legacy: Calls with Andy re proposed stat call with client (0.40); considering query on WS by client and reviewing rules (0.40); email to client on next steps, disclosure and proposed call (0.60); considering

same (1.00), emails and calls re legal memo (0.40); considering next steps and updating team (0.40); Ace Decade: consider emails, order and next step, matter management (0.20) 910 3.40 3,094.00 Jhneil Stewart 23/12/2024 Consider next steps and updating action list (0.40), email to client on proposed call with ULX (0.20), email to team on call agenda (0.20); instructions to ANM on next steps and chaser to court on listing (0.20) 910 1.00 910.00 Jhneil Stewart 23/12/2024 Ace decade: Email update to team on Ace Decade next steps 910 0.40 364.00 Jhneil Stewart 23/12/2024 Email update to AMT on listing of K Legacy trial dates, call with AMT re

James Petkovic 23/12/2024 Ace decade: Attending call with Paul Hastings and updating team on call afterwards (1 hour 20); writing query to James Morgan KC on course of conduct / modus operandi evidence on K‐Legacy and obtaining void ab initio declaration on Ace Decade (0.20) 1045 1.40 1,463.00 Aurelia Matonis 23/12/2024 Calling court re listing of trial and PTR 605 0.40 242.00 Andrew Thorp 23/12/2024 Amended application from JLs re reciprocation 1300 0.40 520.00 Andrew Thorp 23/12/2024 Conference call with PH restated for K legacy and disclosure exercises 1300 0.80 1,040.00

Aurelia Matonis 23/12/2024 Research re 605 1.00 605.00

Andrew Thorp 24/12/2024 Call with PH re position of JLs and direction of application and support

Andrew Thorp 30/12/2024 Draft disclosure parameters and targets for K Legacy claim 1300 0.80 1,040.00 Andrew Thorp 30/12/2024 Call with ph re

Aurelia Matonis 30/12/2024 Calling court re update on listing of the trial and PTR 605 0.40 242.00 Aurelia Matonis 30/12/2024 drafting letter to the other side re disclosure 605 1.20 708.00 Aurelia Matonis 30/12/2024 Preparing 605 2.60 1,573.00 Aurelia Matonis 30/12/2024 Email from client re letter re disclosure 605 0.20 121.00 James Petkovic 30/12/2024 Reviewing and amending associate's disclosure letter regarding K‐ Legacy to the other side. 1045 0.40 418.00 Aurelia Matonis 31/12/2024 Meeting with AMT and JBP re disclosure letter 605 0.20 121.00 Aurelia Matonis 31/12/2024 Updating draft letter to ogier re disclosure 605 0.80 484.00 Andrew Thorp 31/12/2024 Considering strategy in relation to listing and disclosure timings 1300 0.40 520.00 Andrew Thorp 31/12/2024 Draft letter to Ogier regarding witness availability and presence 1300 1.00 1,300.00

30/09/2024 Filing Fee - #058140 - Points of Claim, Origination Application, Draft Order 306.00 06/10/2024 Notary Fees-BVIHCM2024/0454 - Luc A Despins ( In His capacity as Chapter 11 Trustee of Hoo Wan K wok ) v k Legacy Ltd Affidavit of Isobel McNaught on the 1st October 2024 60.00 10/10/2024 Additional filing fees for Originating Application filed on 30 September 2024 200.00 22/10/2024 Transcript dated 01st October 2024 228.00 23/10/2024 Filing fees for Skeleton Argument 14.01 04/10/2024 VIRG - Release/Satisfaction of Charge (BC) 100.00 11/09/2024 Updated Company Search-K Legacy Ltd. 100.00 12/09/2024 Filing Fees for suite of Prohibitory injunction application documents: (Application, draft order, Certificate of Urgency, Evidence, Listing Request Form) 652.01 13/09/2024 Filing Fee for Prohibitory injunction (Exhibit LD-1) 27.00 16/09/2024 Filing Fee for Prohibitory injunction ( Second Affidavit of Luc Despins and Exhibit LD-2) 129.00 17/09/2024 Filing Fee for Prohibitory injunction (Skeleton and authorities bundle) 60.02 17/09/2024 Filing Fee for Prohibitory injunction (Hearing bundle) 32.00 28/10/2024 2nd Affidavit of Isobel McNaught on the 22nd October 2024 60.00 30/10/2024 Company Search-Ace Decade Holdings Limited 250.00 30/10/2024 Company Search-Dawn State Limited 250.00 31/10/2024 Transcript in Claim No. BVIHCM 2024/0454 - Luc A Despin v (1) KLegacy Ltd and (2) Qiang Guo,

07/11/2024 Receipt 058345 - (Supplemental Hearing bundle - OA) filed on 01 Oct 2024 32.00 07/11/2024 Receipt 063191 - Continuation: Application Notice, draft Order, Affidavit filed on 18 October

07/11/2024 Receipt 063193 - (Third Affidavit of Luc Despins and Exhibit) filed on 18 October 2024 129.00 07/11/2024 Receipt 063218 - (Exhibit LD-4 (multiple parts)) filed on 18 October 2024 69.03 07/11/2024 Receipt 063219 for - (Exhibit LD-4) filed on 18 October 2024 25.00 07/11/2024 Receipt 063747 - (Hearing bundle: return date) filed on 22 October 2024 32.00 07/11/2024 Receipt 058331 - (Affidavit of Isobel McNaught and Exhibit IM-1) filed on 01 October 2024 129.00 07/11/2024 Receipt 043313 - (Seal and gag: Bundle) filed on 15 July 2024 32.00 07/11/2024 Receipt 043871 - (Updated hearing Bundle filed 17 July 2024 32.00 07/11/2024 Receipt 045966 - (Disclosure application: Hearing bundle, authorities bundle, and skeleton

07/11/2024 Receipt 043834 - (Seal and gag: Application, draft Order, Affidavit, Exhibit, Listing Request Form and Skeleton Argument) filed on 17 July 2024 129.00

07/11/2024 Receipt 043307 ‐ (Seal and gag: Application, draft Order, Affidavit, Exhibit, Listing Request Form and Skeleton Argument) filed 15 July 2024 647.02

07/11/2024 final settlement of costs for claim no. BVIHCOM2 024/0342 DCA v BTR and NJY. 13,257.50 20/11/2024 Directions Order for sealing 27.00 20/11/2024 ELP Receipt 070707 for 1 x Filing (Directions Order for sealing) 27.00