Guo Wengui / Miles Guo — bankruptcy case · ECF #4157

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., :

Debtors.1 : :

-------------------------------------------------------- x SEVENTH INTERIM FEE APPLICATION COVER SHEET SEVENTH INTERIM FEE APPLICATION COVER SHEET

Interim Application of: Paul Hastings LLP

Bankruptcy Petition Filed: February 15, 2022 (main chapter 11 case) Date of Entry of Retention Orders: August 2, 2022 [Docket No. 668] (effective as of July 8, 2022, as to Individual Debtor) and January 24, 2023 [Docket No. 1376] (effective as of October 11, 2022, as to Genever (BVI) and effective as of November 3, 2022, as to Genever (US))

Fees: \$5,542,465.25 Voluntary Fee Reductions: \$99,319.00 Expenses: \$215,048.30 Voluntary Expense Reductions: \$726.00

Fees Previously Requested: Retainer Request:

Expenses Previously Requested: Expense Detail: Requested Expenses: \$1,919,106.10 Retainer Received: N/A Awarded Expenses: \$1,846,533.13 Copies per page cost: \$0.08 b/w Paid Expenses: \$1,846,533.13 \$0.20 color

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 This Application does not include any fees and expenses related to the month of December 2024. Paul Hastings will include such fees and expenses in its next interim fee application.

3 To date, Paul Hastings has not requested (or received) any payment of its fees and expenses with respect to services provided during the Fee Period.

Date Period Requested Fees Requested Fees Awarded and Paid; Expenses Awarded and Amount

Submitted / Covered Expenses Court Order Paid; Court Order Owing Docket No. Expense Reimbursement Application for the Period from July 8, 2022 through October 31, 20224 3/1/23 7/8/22 - \$0.00 \$63,631.75 Not applicable Awarded: \$63,631.75 \$0.00 Docket No. 10/31/22 Paid:

Special Fee Application (Sanctions) for Services Rendered in Securing Compliance with Court-Authorized Subpoenas5 4/10/23 9/28/22 - \$83,370.26 Awarded: \$83,370.26 \$0.00

First Interim Fee Application for the Period from July 8, 2022 through February 28, 2023 5/30/23 7/28/22 - \$12,326,802.00 \$348,813.54 Awarded: \$11,776,802.00 Awarded: \$348,813.54 \$0.00 Docket No. 2/28/23 Paid: \$11,776,802.00 Paid:

1831 Docket No. 1964, entered Docket No. 1964, entered

Second Interim Fee Application for the Period from March 1, 2023 through June 30, 2023 8/4/23 3/1/23 - \$8,037,720.00 \$213,914.83 Awarded: \$7,982,720.00 Awarded: \$213,914.83 \$1,596,544.00 Docket No. 6/30/23 (net of Paid: \$6,386,176.00 Paid:

2051 \$20,096.25 Docket No. 2190, entered Docket No. 2190, entered

Third Interim Fee Application for the Period from July 1, 2023 through August 31, 2023 10/16/23 7/1/23 - \$3,725,984.25 \$146,137.57 Awarded: \$3,525,984.25 Awarded: \$146,137.57 Docket No. 8/31/23 Paid: \$2,820,787.407 Paid:

2256 Docket No. 2408, entered Docket No. 2408, entered \$705,196.85

4 The First Interim Fee Application excluded the expense reimbursements requested in the Expense Reimbursement Application.

- 5 The First Interim Fee Application and the Second Interim Fee Application included the amounts sought in the Special Fee Application (for the period through February 28, 2023 and the period from March 1 - 10, 2023, respectively). Paul Hastings included these amounts not to recover twice but to ensure payment in the event the HK Parties (defined below) do not comply with the Sanctions Order (defined below). In July 2024, the Trustee received payment in the amount of \$83,370.26 from one of the HK Parties. Given that the Trustee was able to recover these fees from one of the HK Parties, Paul Hastings is not seeking further payment of such fees from the estates. - 6 Due to an inadvertent oversight, the monthly fee statements for January and February 2023 (which were covered in the First Interim Fee Application) did not reflect the voluntary reduction in the hourly rate of the Trustee (from \$1,975 to \$1,860 per hour), resulting in an overstatement of Paul Hastings' fees by \$20,096.25 with respect to these two months. This amount was credited in the Second Interim Fee Application against fees requested therein. - 7 Pursuant to the order granting the Third Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$2,820,787.40. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of July and August 2023 was \$2,980,787.40. The overpayment of \$160,000.00 (i.e., 80% of \$200,000.00) was credited on Paul Hastings' September fee statement.

Date Period Requested Fees Requested Fees Awarded and Paid; Expenses Awarded and Amount

Submitted / Covered Expenses Court Order Paid; Court Order Owing Docket No. Fourth Interim Fee Application for the Period from September 1, 2023 through December 31, 2023 2/19/24 9/1/23 - \$6,911,034.50 \$718,236.31 Awarded: \$6,718,104.50 Awarded: \$714,717.61 \$1,343,620.90

Paid: Paid:

2935 Docket No. 3031, entered Docket No. 3031, entered

Fifth Interim Fee Application for the Period from January 1, 2024 through March 31, 2024 6/24/24 1/1/24 - \$4,141,700.76 \$262,633.83 Awarded: \$4,037,000.70 Awarded: \$259,211.31 \$807,400.14

Paid: 3283 Docket No. 3357, entered Docket No. 3357, entered

Sixth Interim Fee Application for the Period from April 1, 2024 through July 31, 2024 10/15/24 4/1/24 - \$5,053,513.53 \$165,738.27 Awarded: \$4,958,513.53 Awarded: \$163,738.27 \$991,702.71 Docket No. 7/31/24 Paid: \$3,950,396.7711 Paid: \$163,738.2712 3700 Docket No. 3814, entered Docket No. 3814, entered on

Total Awarded: \$39,082,495.24 Awarded: \$1,846,533.13 \$5,444,464.60 Paid: \$33,621,616.59 Paid:

8 Pursuant to the order granting the Fourth Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$5,374,483.60, of which \$160,000.00 was applied as a credit pursuant to the order granting the Third Interim Fee Application.

9 Pursuant to the order granting the Fifth Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$3,229.600.56 in fees. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of January, February, and March 2024 was \$3,333,307.41. The overpayment of \$103,706.85 was credited on Paul Hastings' April 2024 fee statement.

10 Pursuant to the order granting the Fifth Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$259,211.31 in expenses. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for expenses incurred during the months of January, February, and March 2024 was \$262,633.83. The overpayment of \$3,422.52 was credited on Paul Hastings' April 2024 fee statement.

11 Pursuant to the order granting the Sixth Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$3,966,810.82 in fees. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of April, May, June, and July was \$4,054,103.62 in fees (inclusive of the \$103,706.85 credit for fee reductions pursuant to the Fifth Interim Fee Application). The overpayment of \$87,292.80 is being credited in this Application.

12 Pursuant to the order granting the Sixth Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$163,738.27 in expenses. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for fees incurred during the months of April, May, June, and July was \$165,738.27 in fees (inclusive of the \$3,422.52 credit for expense reductions pursuant to the Fifth Interim Fee Application). The overpayment of \$2,000.00 is being credited in this Application.

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13 On August 18, 2023, the Court entered the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals [Docket No. 2094] (the "Interim Compensation Procedures Order"), pursuant to which estate professionals (including Paul Hastings) commenced filing monthly fee statements.

14 As detailed below, as an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of twelve (12) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$10,119.00. HOURS AND RATES PER PROFESSIONAL AND PARAPROFESSIONAL DURING FEE PERIOD15

Bassett, Nicholas Corporate, 2007 \$1,835.00 438.00 \$803,730.00 3 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$917.50 20.20 \$18,533.50 3 Despins, Luc Restructuring, 1986 \$1,975.00 354.20 \$699,545.00 1 Despins, Luc (travel; ½ rate) Restructuring, 1986 \$987.50 4.40 \$4,345.00 1 Tsao, Leo Litigation, 1999 \$1,775.00 32.30 \$57,332.50 2

Bongartz, Alex Restructuring, 2007 \$1,850.00 244.20 \$451,770.00 3 Bongartz, Alex (travel, ½ rate) Restructuring, 2007 \$925.00 1.20 \$1,110.00 3 Maza, Shlomo Corporate, 2012 \$1,850.00 382.00 \$706,700.00 3 Traxler, Katherine Restructuring, 1990 \$1,120.00 8.10 \$9,072.00 3

Barron, Douglass Corporate, 2012 \$1,395.00 659.40 \$919,863.00 3 Catalano, Kristin Corporate, 2021 \$1,185.00 139.20 \$164,952.00 3 Farmer, Will Corporate, 2018 \$1,390.00 52.30 \$72,697.00 3 Kim, Sarah Litigation, 2023 \$985.00 11.90 \$11,721.50 1 Kosciewicz, Jon Litigation, 2021 \$1,185.00 93.50 \$110,797.50 3 Rubinfeld, Mila Corporate, 2021 \$565.00 12.50 \$7,062.50 N/A Sadler, Tess Corporate, 2019 \$1,365.00 37.10 \$50,641.50 3 Simon, Tori Corporate, 2024 \$795.00 38.10 \$30,289.50 N/A Song, Luyi Corporate, 2023 \$985.00 678.80 \$668,618.00 3 Song, Luyi (travel; ½ rate) Corporate, 2023 \$492.50 3.10 \$1,526.75 3 Sutton, Ezra Corporate, 2021 \$1,270.00 439.50 \$558,165.00 3 Sutton, Ezra (travel, ½ rate) Corporate, 2021 \$635.00 0.90 \$571.50 3 Associate Total 2,166.30 \$2,596,905.75

Boyle, Terrence Paralegal \$565.00 6.80 \$3,842.00 N/A Doherty, Allison Paralegal \$445.00 24.30 \$10,813.50 N/A Laskowski, Mat Paralegal \$565.00 25.60 \$14,464.00 2 Mohamed, David Paralegal \$565.00 290.80 \$164,302.00 2 Paraprofessional Total 347.50 \$193,421.50

15 Reflects reduction of \$10,119.00 for fees of twelve (12) timekeepers who billed less than five (5) hours during the Fee Period. UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

-------------------------------------------------------- x SEVENTH INTERIM FEE APPLICATION OF PAUL HASTINGS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM AUGUST 1, 2024 THROUGH NOVEMBER 30, 2024

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (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 [Docket No. 2094] (the "Interim Compensation Procedures Order"), Paul Hastings LLP ("Paul Hastings"), as counsel to (a) 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"), (b) Genever Holdings Corporation ("Genever (BVI)"), and (c) Genever Holdings LLC ("Genever (US)" and, together with Genever (BVI), the "Genever Debtors"), hereby files this

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).

*Seventh Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from August 1, 2024 through November 30, 2024* (the "Application"). By this Application, Paul Hastings requests allowance and payment2 of the compensation for professional services performed by Paul Hastings attorneys (including the Trustee3 ) and reimbursement of its actual and necessary expenses incurred during the period from August 1, 2024 through and including November 30, 2024 (the "Fee Period"). In support of this Application, Paul Hastings respectfully states as follows:

1. During the Fee Period, the Trustee and Paul Hastings continued the investigation into the financial affairs of the Individual Debtor and his corporate "shell game" to shield companies and assets under his ownership and/or control from his creditors. Given the vast network of companies affiliated with the Individual Debtor, and the fact that these companies or their assets are located around the world, the Trustee's investigation continues to be extensive. As the Court is also aware, during the Fee Period, the Trustee also continued to prosecute, with the assistance of Paul Hastings and the Trustee's other advisors, numerous adversary proceedings asserting alter ego and equitable ownership claims (or similar claims under

2 To date, Paul Hastings has not requested (or received) any payment of its fees and expenses with respect to services provided during the Fee Period. In addition, while this Application seeks allowance of all fees incurred during the Fee Period (other than with respect to the civil RICO action), Paul Hastings is only seeking payment, at this time, of (i) 80% of such fees (in addition to 100% of the expenses incurred during the Fee Period).

3 In accordance with the Retention Order (as defined below), the Trustee is authorized to act as one of the attorneys for the Individual Debtor's estate, and, accordingly, this Application also seeks allowance of the Trustee's fees in such capacity. For the avoidance of doubt, in this Application, references to services provided by Paul Hastings attorneys shall include the Trustee. To be clear, time spent by the Trustee in his capacity as chapter 11 trustee, is not part of this Application, and compensation therefor will be sought by separate application.

4 Capitalized terms used in the preliminary statement have the meanings ascribed to such terms later in this Application.

applicable law) as well as more than 300 adversary proceedings seeking to avoid fraudulent

transfers and postpetition transfers (the "Avoidance Actions").

2. As part of the Trustee's efforts to recover assets for the benefit of the estates, the

Trustee continued to make substantial progress, including in several pending adversary

proceedings and appeals. For example:

- Greenwich Land Adversary Proceeding: During the Fee Period, Paul Hastings continued to prosecute the Trustee's adversary proceeding against Greenwich Land LLC ("Greenwich Land") and the Individual Debtor's alleged wife (i.e., Hing Chi Ngok), seeking determinations that, among other things, (a) Greenwich Land (which holds legal title to the Individual Debtor's residence in Greenwich, Connecticut) is an alter ego of the Debtor and (b) the Debtor is the equitable owner of Greenwich Land. On July 3, 2024, the Court granted the Trustee's motion for summary judgment, holding, among other things, that Greenwich Land is an alter ego of the Individual Debtor and directing that the property of Greenwich Land be turned over to the estate. As a result of this ruling, among other things, the multi-million-dollar mansion located at 373 Taconic Road, Greenwich, Connecticut (the "Taconic Property") became property of the estate - o On October 15, 2024, the Court granted the Trustee's motion to sell the Taconic Property for \$7.25 million - Mahwah Adversary Proceeding: During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC ("Taurus Fund"), and Taurus Management LLC following the lifting of the stay on August 1, 2024. In this adversary proceeding, the Trustee seeks determinations that, among other things, (a) the Individual Debtor is the equitable owner of a 50,000 square foot, castle-styled private residence with 12.5-acre grounds located at 675 Ramapo Valley Road, Mahwah, New Jersey 07430 (the "Mahwah Mansion"), (b) the Debtor is the equitable owner of Taurus Fund (the entity holding title to the Mahwah Mansion), and (c) that Taurus Fund is an alter ego of the Individual Debtor. - o On September 11, 2024, the Trustee filed the motion for summary judgment, accompanied by a voluminous evidentiary record supporting the Trustee's motion which includes a statement of undisputed facts containing 56 paragraphs and citing to 279 exhibits and the testimony of more than 15 witnesses, either by way of deposition transcript or in-court testimony. Paul Hastings attorneys also prepared and filed the Trustee's reply to the defendants' opposition on the motion for summary judgment.

A hearing on the Trustee's summary judgment was held on November 19, 2024.

- o On October 1, 2024, the Trustee filed motion for authorization to market and sell the Mahwah Mansion and its contents (subject to certain conditions). On October 29, 2024, the Court entered an order granting the Trustee's motion. The Trustee's efforts to sell the Mahwah Mansion are ongoing. - Lamp Capital Adversary Proceeding: During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding seeking, among other things, determination that Lamp Capital LLC ("Lamp Capital"), Hudson Diamond NY LLC ("Hudson Diamond"), and Leading Shine NY Ltd. ("Leading Shine") are the Individual Debtor's alter egos and that the Individual Debtor equitably owns these defendants and their assets. - o On September 19, 2024, the Trustee filed the motion for summary judgment as to Trustee's claims against Hudson Diamond and Leading Shine, which includes a statement of undisputed facts containing 29 paragraphs and citing to 130 exhibits. Paul Hastings attorneys also prepared and filed the Trustee's reply to the defendant's opposition to the summary judgment motion. A hearing on the Trustee's summary judgment motion was held on December 10, 2024 (i.e., after the Fee Period), and the matter is currently under advisement by this Court. - Defeng Cao Adversary Proceeding: During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint seeking determinations that six separate vehicles—three Harley Davidsons and one BMW motorcycle, as well as one Land Rover Defender and one Dodge Ram Pickup Truck—which, while nominally held by the defendant, were fraudulently transferred to Defeng Cao (Mei Guo's long-term boyfriend), or alternatively, are equitably owned by the Individual Debtor. - o On September 9, 2024, the Court granted the Trustee's motion for judgment on the pleadings, holding that the motorcycles are property of the estate and requiring Mr. Cao to turn them over to the estate. - VCTR Shares: Through his investigation of the Individual Debtor's financial affairs, the Trustee learned that Lamp Capital—which the Court found to be an alter ego of the Individual Debtor—owns a limited partnership interest in the Reverence Capital Partners Opportunities Fund I (Cayman) L.P. (the "Reverence Fund"). The interest—which is property of the estate—includes rights to receive distributions from the publicly traded VCTR Shares and unpaid cash distributions. On June 12, 2024, the Court granted the Trustee's motion, holding, among other things, that the limited partnership interest is property of the estate, and approving the liquidation of the VCTR Shares and distribution of net proceeds to the Trustee for the benefit of the estate. - o On August 6, 2024, the Trustee filed a report noting that on July 31, 2024, he received for the benefit of the estate a distribution from Reverence Fund in the amount of more than \$2.7 million - Omnibus Alter Ego Adversary Proceedings: During the Fee Period, Paul attorneys continued to pursue the Trustee's adversary proceeding against various entities, including K Legacy Ltd. ("K Legacy"), seeking declarations that such entities are alter egos of the Individual Debtor and/or their assets are beneficially owned by the Individual Debtor, such that their assets are property of the estate. - o On September 12, 2024, the Trustee obtained entries of default as against K Legacy and the Debtor's son, i.e., Qiang Guo, pursuant to which the Court held, among other things, that the ownership interests in K Legacy and the assets of K Legacy, including a luxury apartment in London, are property of the estate. - o In addition to the default judgment against K Legacy and the Debtor's son, the Trustee has also commenced separate proceedings in the British Virgin Islands ("BVI"), i.e., the jurisdiction where K Legacy is incorporated, to, among other things, seek rulings that the Trustee beneficially owns K Legacy and the London apartment. - o On October 29, 2029, Paul Hastings filed the Trustee's amended complaint in the omnibus alter ego litigation, and, on December 6, 2024, Paul Hastings filed the Trustee's objection to certain defendants' motions to dismiss the amended complaint. - o On September 13, 2024, the Clerk of the Bankruptcy Court entered a default against more than 15 defendants. On November 26, 2024, upon the Trustee's motion for entry of consented to stipulated judgment, the Court entered the stipulated judgment as to defendant Karin Maistrello. - o On December 23, 2024, the Trustee commenced a new adversary proceeding against more than 40 entities seeking rulings that such entities are alter egos of the Individual Debtor and/or their assets are beneficially owned by the Individual Debtor under applicable law, such that their assets are property of the estate. - Ace Decade Adversary Proceeding: During the Fee Period, Paul Hastings continued to handle the Trustee's adversary proceeding against Ace Decade Holdings Limited ("Ace Decade"), Yvette Wang, and Rui Hao seeking a declaration that the transfer of the Ace Decade share by Yvette Wang to Rui Hao is void ab initio because it violates the Bankruptcy Code's automatic stay. - o On September 12, 2024, the Court entered a default judgment against Rui Hao. - o The Trustee has also learned that, in June 2024, Defendant Hao initiated liquidation proceedings in the BVI with respect to Ace Decade and its wholly owned subsidiary Dawn State Limited ("Dawn State"). Accordingly, Paul Hastings' also had to address the BVI liquidation proceedings as part of the Trustee's continuing efforts to obtain ownership and control over Ace Decade and Dawn State. To that end, during the Fee Period, Paul Hastings attorney handled a variety of issues, in coordination with the Trustee's BVI counsel, relating to these proceedings in the BVI. - Mei Guo Adversary Proceeding: During the Fee Period, Paul Hastings continued, in coordination with the Trustee's local Connecticut counsel, Neubert Pepe & Monteith, P.C. ("NPM"), to prosecute the Trustee's adversary proceeding against Mei Guo. In this adversary proceeding, the Trustee seeks determinations that, among other things, (a) more than \$10 million in proceeds from the sale of the Individual Debtor's private Bombardier jet are property of the estate and (b) a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate. On April 3, 2024, the Court granted, in part, the Trustee's motion for summary judgment, holding, among other things, that the Individual Debtor beneficially owned the Bombardier jet and, hence, beneficially owns the Bombardier proceeds, and directing Mei Guo to turn over to the estate the Bombardier proceeds. Following the Court's decision, more than \$10 million in Bombardier proceeds were turned over to the estate. - o During the Fee Period, Paul Hastings attorneys analyzed issues relating to Mei Guo's violation of the preliminary injunction order issued by this Court in the Mei Guo Adversary Proceeding and prepared the Trustee's motion to enforce the preliminary injunction, which was filed on December 20, 2024. - Appeals: The Trustee also made significant progress in the various appeals of order of this Court. For example: - o On August 23, 2024, the United States District Court for the District of Connecticut (the "District Court") affirmed this Court's orders granting the Trustee's motion for summary judgment in which this Court determined that the Individual Debtor was the beneficial owner of the Lady May yacht and that HK International Funds Investment (USA) Limited, LLC ("HK USA") was the Individual Debtor's alter ego. - o Paul Hastings attorneys spent significant time briefing the proposed intervenors' appeal of this Court's order denying their motion to intervene in the HCHK Adversary Proceeding. On August 29, 2024, after briefing

concluded, the proposed intervenors filed a stipulation dismissing the appeal with prejudice.

- o Paul Hastings attorneys also prepared the Trustee's brief in the HCHK entities' related appeal of this Court's order granting default judgment against such entities. After briefing concluded, the HCHK entities' counsel withdrew its appearance in the appeal and on October 24, 2024, the District Court entered an order of dismissal of the appeal case. On November 1, 2024, Clerk of the District Court entered judgment of dismissal. - o On September 30, 2024, the District Court affirmed this Court's preliminary injunction order against the Individual Debtor and those within his control prohibiting the intimidation and harassment of the Trustee and PAX during the protest activities. - o On November 15, 2024, Paul Hastings filed the Trustee's brief in the United States Court of Appeal for the Second Circuit in connection with the appeal of the District Court's order affirming the Bankruptcy Court's order holding HK USA and Mei Guo in contempt for failure to comply with order compelling production. - o On December 31, 2024 (i.e., after the Fee Period), Paul Hastings filed the Trustee's brief in Greenwich Land and Ms. Ngok's appeal of the Bankruptcy Court's summary judgment decision in the Greenwich Land Adversary Proceeding. - o On January 21, 2024 (i.e., after the Fee Period), the District Court issued a memorandum of decision affirming the Bankruptcy Court's summary judgment order in the Mei Guo Adversary Proceeding finding that the Individual Debtor was the beneficial owner of the Bombardier jet and Whitecroft Shore Limited, and that the proceeds from the sale of the Bombardier jet as well as Mei Guo's ownership interest in Whitecroft are property of the estate and must be turned over to the Trustee. - Motions to Withdraw References: Paul Hastings attorneys also continued to work on responses to several defendants' motions to withdraw the reference. For example: - o On August 30, 2024, the Trustee filed his objection to the motion to withdraw the reference of the Mahwah Adversary Proceeding filed by Taurus Fund, Taurus Management LLC, and Scott Barnett. - o On January 2, 2025 (i.e., after the Fee Period), the District Court issued a memorandum of decision denying the motion to withdraw the reference by Greenwich Land and Ms. Ngok. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 13 of 879

3. Furthermore, during the Fee Period, the Trustee, with the assistance of Paul Hastings and the Trustee's other advisors, continued his global investigations into the Individual Debtor's financial affairs and made progress in his investigation and recovery efforts in foreign jurisdictions, including the United Kingdom, BVI, Switzerland, Mauritius, and the United Arab Emirates ("UAE").

4. Moreover, during the Fee Period, the Trustee and his professionals continued to prosecute approximately 300 Avoidance Actions and handled issues including (a) analyzing potential avoidance claims, (b) preparing and filing additional Avoidance Action complaints and the Trustee's responses to Avoidance Action defendants' motions to dismiss, (c) preparing the Trustee's opposition to Avoidance Action defendants' motion to withdraw the reference, (d) meeting and conferring with counsel for Avoidance Action defendants, (e) developing strategies for potential settlements, (f) participating in mediation and conducting settlement negotiation, and (g) handling hearings and status conferences in such Avoidance Actions. Furthermore, on November 13, 2024 and November 20, 2024, respectively, the Bankruptcy Court granted the Trustee's motions for entry of default judgment in Avoidance Actions against Qiang Guo, the Debtor's son, with respect to more than \$20 million transfer from the Individual Debtor's alter ego, Lamp Capital, to Qiang Guo, and approximately \$4 million transfers from the Individual Debtor's alter egos, Lamp Capital, HCHK Technologies, Inc., and Leading Shine, for the benefit of Qiang Guo.

5. In addition, during the Fee Period, the Trustee and his professionals continued to prepare for and conduct mediation and settlement negotiations with respect to pending avoidance actions, and conferred with the mediator, U.S. Bankruptcy Judge James J. Tancredi, about the mediation processes. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 14 of 879

6. Given the enormity of the Trustee's task and the continued obstruction by the Debtors' associates and alter ego companies, coupled with the delay in Trustee's investigation caused by the Individual Debtor's criminal trial (see below), it was impossible for the Trustee to complete his investigation and assert all available causes of action prior to February 15, 2025 (i.e., the extended deadline granted by the Court on August 14, 2024). For that reason, Paul Hastings, in coordination with NPM, prepared the Trustee's motion to extend the February 15, 2025 deadline for the Trustee to commence actions to avoid and recover fraudulent transfers and/or assert other estate causes of action (which motion was filed on July 19, 2024). The Court held an evidentiary hearing on August 13, 2024 and granted this motion by order dated August 14, 2024.5

7. In addition, as part of the Trustee's investigation, the Trustee continued to monitor the criminal case (the "Criminal Case") against the Individual Debtor and Yvette Wang in the United States District Court for the Southern District of New York [Case No. 1:23-cr-00118-AT] (the "SDNY Court"). As the Court is aware, the Individual Debtor was found guilty on nine counts following a jury trial (the "Criminal Trial"), while Yvette Wang pled guilty and was recently sentenced to ten years in prison. The Individual Debtor's sentencing hearing is pending. The Criminal Trial made public thousands of government exhibits, which contain important information that the Trustee had not learned in discovery and supplemented the Trustee's ongoing investigation efforts. During the Fee Period, Paul Hastings attorneys continued to review these exhibits and analyze various legal issues related to the criminal forfeiture allegations of over \$630 million in assets seized by the U.S. Government in the Individual Debtor's Criminal Case.

5 Recently, the Court has further extended the deadline to August 15, 2025 [Docket No. 4106]. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 15 of 879

8. Furthermore, during the Fee Period, the Trustee and Paul Hastings continued to handle the remediation and cleaning efforts following the fire on March 15, 2023 at the 18th floor apartment at the Sherry Netherland (the "Sherry Netherland Apartment"). Among other things, Paul Hastings attorneys worked with Genever (US)'s architect (Acheson Doyle) and other service providers to conduct the remediation of soot and other combustion by-products and ancillary services at the Sherry Netherland Apartment. The remediation and cleaning projects were substantially completed in August 2024, such that, beginning in September 2024, the Trustee began marketing the Sherry Netherland Apartment.

9. All the while, during the Fee Period, the Trustee and Paul Hastings provided a wide range of other chapter 11 related services, including, for example, handling ten hearings and status conferences, preparing and prosecuting numerous substantive motions, and preparing monthly operating reports.

10. As detailed in this Application, Paul Hastings has performed all of its services in an economic, effective, and efficient manner commensurate with the complexity and importance of the issues involved. The work performed by Paul Hastings was carefully assigned to appropriate professionals or paraprofessionals according to the experience and level of expertise required for each particular task. Whenever possible, Paul Hastings sought to minimize the costs of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. Moreover, as detailed below, Paul Hastings has delegated numerous work streams (including the recent avoidance actions process) to local Connecticut counsel (which has a lower rate structure than Paul Hastings).

11. To further minimize the costs of intra-Paul Hastings communications and education about these chapter 11 cases, the Trustee utilized a small group of Paul Hastings Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 16 of 879

attorneys for the majority of the work in these chapter 11 cases. Also, as a general matter, in addition to the Trustee, no more than two Paul Hastings attorneys attended the various hearings held during the Fee Period (and in some instances, the Trustee handled hearings without attendance of any Paul Hastings attorneys), thereby minimizing not only the time billed on these hearings/sessions but also the cost of travel. Moreover, as noted on the record at the August 2, 2022 hearing on Paul Hastings' retention application, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

12. Finally, as an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of thirteen (13) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$10,690.50. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

13. In sum, Paul Hastings respectfully submits that the services for which it seeks compensation in this Application were necessary for and beneficial to these chapter 11 estates and their stakeholders. Accordingly, in light of the nature and complexity of these chapter 11 cases, Paul Hastings' charges for professional services performed and expenses incurred are reasonable under applicable standards. For all these reasons, Paul Hastings respectfully requests that the Court grant the Application and allow interim compensation for professional services performed and reimbursement for expenses as requested. JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

14. 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.

15. The legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Bankruptcy Rule 2016-1.

16. Paul Hastings believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, the Interim Compensation Procedures Order, 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").6 Paul Hastings respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 17. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains disclosures regarding "customary and comparable compensation." - Exhibit B1 contains a summary of Paul Hastings' timekeepers included in this Application. - Exhibit B2 contains a summary of Paul Hastings' timekeepers who billed less than five (5) hours during the Fee Period and for whom Paul Hastings is not seeking allowance or payment at this time. - Exhibit C contains a summary of the compensation requested by project category. - Exhibits D-1 and D-2 contain a summary of the compensation requested by Matter ID.

6 Paul Hastings 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 E contains the expense reimbursements requested by category. - Exhibit F contains the monthly statements of Paul Hastings detailing the services performed and itemizing the expenses incurred during the Fee Period. - Exhibit G contains the Proposed Order.

18. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed with the Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

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

20. On June 15, 2022, the Court entered a memorandum of decision and order [Docket No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the chapter 11 case of Ho Wan Kwok. 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 chapter 11 case of Ho Wan Kwok.

21. The Court authorized Paul Hastings' retention as attorneys for the Trustee pursuant to the *Order Authorizing and Approving the Retention and Employment of Paul Hastings LLP as Counsel to Chapter 11 Trustee, effective as of July 8, 2022* [Docket No. 668] (together with the retention order with respect to the Genever Debtors [Docket No. 1376], the "Retention Order"), entered on August 2, 2022. The Retention Order authorizes Paul Hastings 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 Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 19 of 879

Local Bankruptcy Rules, and such orders as the Court may direct. Moreover, at the August 1, 2022 hearing on the Paul Hastings' retention application, the Court made clear that it approved Paul Hastings' New York rate structure.7 In addition, as noted on the record at that hearing, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

22. In light of the Trustee's ongoing investigation into the Individual Debtor's assets and his financial affairs, the Trustee is unable at this time to predict when he will be in a position to file a plan and disclosure statement. All quarterly fees have been paid to the United States Trustee, and all monthly operating reports have been filed through August 2024 (for each of the Individual Debtor's chapter 11 case, Genever (BVI)'s chapter 11 case, and Genever (US)'s chapter 11 case).

23. At this time, the amount of cash in the Trustee's account is approximately \$74.4 million. The Trustee is not aware of any material administrative expense claims other than claims for professional fees and expenses.

24. On October 11, 2022, Genever (BVI) -- an entity wholly owned by the Individual Debtor -- filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

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

7 See Aug. 1, 2022 H'rg Tr. at 113:15-19 ("MR. DESPINS: But I want to be clear is that that's not going to be a back door way to bring local rates, or anything like that -- THE COURT: No, I'm not doing that. I agree with that."). Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 20 of 879

26. 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 [Docket No. 970].

27. On January 24, 2023, the Court granted Genever (BVI)'s application to retain Paul Hastings as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., October 11, 2022 [Docket No. 1376].

28. On October 12, 2020, Genever Holdings LLC -- an entity wholly owned by Genever (BVI) -- filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code in the United States Bankruptcy Court for the Southern District of New York (the "SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG) (the "SDNY Bankruptcy Case").

29. On November 3, 2022, the SDNY Bankruptcy Court entered an order [Docket No. 225 in Case No. 22-50592] transferring the venue of the SDNY Bankruptcy Case to this Court, which assigned it Case Number 22-50592.

30. On November 21, 2022, the Court entered an order granting joint administration of the Genever (US) Debtor's chapter 11 case with the jointly administered cases of the Individual Debtor and the Genever (BVI) Debtor's chapter 11 case [Docket No. 1141].

31. On January 24, 2023, the Court granted Genever (US)'s application to retain Paul Hastings as counsel to Genever (US) in its chapter 11 case, effective as of the order transferring venue of the SDNY Bankruptcy Case to this Court, i.e., November 3, 2022 [Docket No. 1376].

32. By this Application, the Trustee and Paul Hastings request allowance of fees (in the amount of \$5,552,587.25) and expenses incurred (in the amount of \$215,048.30) for services

rendered by, for, and on behalf of the Trustee during the Fee Period. The Trustee has approved the amounts requested by Paul Hastings herein.

33. While this Application seeks allowance of all fees incurred during the Fee Period,

Paul Hastings only seeks, at this time, payment of 80% of the fees and 100% of the expenses—

i.e., Paul Hastings does not seek, at this time, payment of the 20% holdback withheld by the

Debtors' estates with respect to Fee Period.8

34. To date, the Trustee and Paul Hastings have submitted the following fee/expense-

related applications in these chapter 11 cases:

- (a) On March 1, 2023, Paul Hastings submitted the *First Interim Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Reimbursement of Expenses for the Period from July 8, 2022 through October 31, 2022* [Docket No. 1495] (the "Expense Reimbursement Application"), whereby the Trustee and Paul Hastings requested reimbursement of the actual and necessary expenses incurred by the Trustee and Paul Hastings during the period from July 8, 2022 through October 31, 2022 in the amount of \$63,631.75. On May 3, 2023, the Court entered an order granting the Expense Reimbursement Application [Docket No. 1747] (the "Expense Reimbursement Order"). The Individual Debtor's estate paid the foregoing amount on May 8, 2023. - (b) On April 10, 2023, Paul Hastings submitted the Special Fee Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Services Rendered in Securing Compliance with Court-Authorized Subpoenas [Docket No. 1648] (the "Special Fee Application"). In the Special Fee Application, Paul Hastings requested allowance and payment of fees in the amount of \$83,370.26 in accordance with the HK Parties Contempt Order.9 On April 21, 2023, the Court approved the Special Fee Application and ordered the HK Parties to remit payment of \$83,370.26 to the chapter 11 estate of the Individual Debtor [Docket

8 In this Application Paul Hastings is not seeking allowance or payment of fees or reimbursement of expenses with respect to the Civil RICO Adversary Proceeding. Paul Hastings intends to seek allowance and payment of such fees and expenses in the future.

9 On March 10, 2023, the Court entered the *Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC* [Docket No. 1537] (the "HK Parties Contempt Order"), pursuant to which the Court ordered Ms. Mei Guo, HK International Funds Investments (USA) Limited ("HK USA"), attorney Lee Vartan, and Chiesa Shahinian & Giantomasi PC (collectively, the "HK Parties"), jointly and severally, to compensate the Trustee and his counsel, Paul Hastings, for reasonable attorneys' fees and expenses associated with the Trustee's efforts to secure compliance with certain Courtauthorized subpoenas.

No. 1693] (the "HK Parties Sanctions Order"). The United States District Court for the District of Connecticut has affirmed the HK Parties Sanctions Order. In July 2024, the Trustee received payment in the amount of \$83,370.26 from one of the HK Parties.

- (c) On May 30, 2023, Paul Hastings submitted the *Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 8, 2022 through February 28, 2023* [Docket No. 1831] (the "First Interim Fee Application") seeking \$12,326,802.00 in fees and \$348,813.54 for reimbursement of expenses. The First Interim Fee Application excluded the expense reimbursements approved in the Expense Reimbursement Order. The First Interim Fee Application included the amount requested in the Special Fee Application (for the period through February 28, 2023).10 Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$550,000. On June 29, 2023, the Court approved the First Interim Fee Application [Docket No. 1964] with such reduction. Paul Hastings has received payment of \$11,776,802.00 in fees and \$348,813.54 in expenses in connection with the First Interim Fee Application. - (d) On August 4, 2023, Paul Hastings submitted the *Second Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from March 1, 2023 through June 30, 2023* [Docket No. 2051] (the "Second Interim Fee Application") seeking \$8,037,720.00 in fees and \$213,914.83 for reimbursement of expenses. The Second Interim Fee Application included the amount requested in the Special Fee Application (for the period from March 1, 2023 through March 10, 2023). Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$55,000.00. On September 12, 2023, the Court approved the Second Interim Fee Application [Docket No. 2190] with such reduction. Paul Hastings has received payment of \$6,386,176.00 in fees (or 80% of the allowed fees in the amount of \$7,982,720) and \$213,914.83 in expenses in connection with the Second Interim Fee Application. - (e) On October 16, 2023, Paul Hastings submitted the *Third Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 1, 2023 through August 31, 2023* [Docket No. 2256] (the "Third Interim Fee Application") seeking \$3,725,984.25 in fees and \$146,137.57 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$200,000.00. On November 30, 2023, the Court entered an order [Docket No. 2408] approving the Third Interim Fee Application with such reduction. Paul Hastings has received payment of

10 Given that the Trustee was able to recover the fees under the HK Parties Sanctions Order from the HK Parties, Paul Hastings is not seeking further payment of such fees from the estates.

\$2,820,787.4011 in fees (or 80% of the allowed fees in the amount of \$3,525,984.25) and \$146,137.57 in expenses in connection with the Third Interim Fee Application.

- (f) On February 19, 2024, Paul Hastings submitted the *Fourth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from September 1, 2023 through December 31, 2023* [Docket No. 2935] (the "Fourth Interim Fee Application") seeking \$6,911,034.50 in fees and \$718,236.31 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$192,930.00 and its expense reimbursement request by \$3,518.70. On March 21, 2024, the Court entered an order [Docket No. 3031] approving the Fourth Interim Fee Application with such reductions. Paul Hastings has received payment of \$5,374.483.60 in fees (or 80% of the allowed fees in the amount of \$6,718,104.50) and \$714,717.61 in expenses in connection with the Fourth Interim Fee Application. - (g) On June 24, 2024, Paul Hastings submitted the *Fifth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from January 1, 2024 through March 31, 2024* [Docket No. 3283] (the "Fifth Interim Fee Application") seeking \$4,141,700.76 in fees and \$262,633.83 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$104,700.00 and its expense reimbursement request by \$3,422.52. On July 26, 2024, the Court entered an order [Docket No. 3357] approving the Fifth Interim Fee Application with such reductions. Paul Hastings has received payment of \$3,229,600.5612 in fees (or 80% of the allowed fees in the amount of \$4,037,000.70) and \$259,211.31 in expenses in connection with the Fifth Interim Fee Application. - (h) On October 15, 2024, Paul Hastings submitted the *Sixth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from April 1, 2024 through July 31, 2024* [Docket No. 3700] (the "Sixth Interim Fee Application") seeking \$5,053,513.53 in fees and \$165,738.27 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$87,292.80 and its expense reimbursement request by \$2,000.00. On November 13, 2024, the Court entered an order [Docket No. 3814] approving the Sixth Interim Fee Application with such reductions. Paul Hastings has received payment of \$3,966,810.8213 in fees

11 Pursuant to the Interim Compensation Procedures Order, Paul Hastings had previously received \$2,980,787.40 in payments for fees incurred in July and August 2023. Accordingly, as part of its September 2023 monthly fee statement, Paul Hastings included a credit of \$160,000.00 (i.e., 80% of the agreed-upon \$200,000.00 reduction).

12 Pursuant to the Interim Compensation Procedures Order, Paul Hastings had previously received \$3,333,307.41 in payments for fees incurred in January, February, and March, 2024. Accordingly, as part of its April 2024 monthly fee statement, Paul Hastings included a credit of \$103,706.85.

13 Pursuant to the Interim Compensation Procedures Order, Paul Hastings had previously received \$4,054,103.62 in fees (inclusive of the \$103,706.85 credit for fee reductions pursuant to the Fifth Interim Fee Application) in

(or 80% of the allowed fees in the amount of \$4,958,513.53) and \$163,738.2714 in expenses in connection with the Sixth Interim Fee Application.

(i) To date, Paul Hastings has not submitted monthly fee statements for services rendered during the Fee Period, and, accordingly, Paul Hastings has not received payment with respect to services provided and expenses incurred during the Fee Period.

35. Neither the Trustee nor Paul Hastings has received any payment or promise of payment from any source for services rendered during the Fee Period. There is no agreement or understanding between the Trustee and/or Paul Hastings and any other person other than the attorneys, employees, and staff of Paul Hastings, for the sharing of compensation to be received for services rendered in these chapter 11 cases.

36. Paul Hastings' professional services during the Fee Period required an aggregate expenditure of 3,998.40 recorded hours by attorneys and paraprofessionals, broken down as follows: partners (849.10 hours), of counsel (635.50 hours), associates (2,166.30 hours), and paraprofessionals (347.50 hours). The timekeepers who rendered such services are identified in the Cover Sheet hereto, along with the number of hours and the total compensation sought for each individual.

37. Paul Hastings maintains computerized records, in the form of monthly statements, of the time spent by all Paul Hastings' attorneys and paraprofessionals in connection with its representation of the Trustee and the Genever Debtors. With the exception of the monthly

payments for fees incurred in April, May, June, and July 2024. Accordingly, as part of this Application, Paul Hastings is not seeking payment of \$87,292.80 (i.e., the difference between \$4,054,103.62 and \$3,966.180.82).

14 Pursuant to the Interim Compensation Procedures Order, Paul Hastings had previously received \$165,738.27 in expense reimbursements (inclusive of the \$3,422.52 credit for expense reductions pursuant to the Fifth Interim Fee Application) in payments for fees incurred in April, May, June, and July 2024. Accordingly, as part of this Application, Paul Hastings is not seeking payment of \$2,000.00 (i.e., the difference between \$165,738.27 and \$163,738.27). Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 25 of 879

statements submitted with the Special Fee Application,15 the monthly statements are in the same form regularly used by Paul Hastings to bill its clients for services rendered and include the date that the services were rendered, a detailed, contemporaneous narrative description of the services provided, the amount of time spent for each service, and the designation of the professional who performed the service. Attached hereto as Exhibit F are true and correct copies of the monthly statements of Paul Hastings related to the fees requested herein.

38. As a courtesy to these estates and based on circumstances unique to these chapter 11 cases, Paul Hastings agreed on a reduced hourly rate for Luc Despins (from his standard hourly rate of \$2,225.00 to the reduced hourly rate of \$1,975.00) for the Fee Period.16 Other than this discount, the rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. In addition, when Paul Hastings' restructuring professionals and paraprofessionals work on non-bankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable non-bankruptcy cases in a competitive national legal market.

39. Paul Hastings respectfully submits that the reasonable value of the services rendered by Paul Hastings (including the Trustee) during the Fee Period is \$5,542,465.25.

15 As noted in the Special Fee Application, Paul Hastings' monthly statements for fees incurred in securing compliance with the Court-authorized subpoenas are limited to those services and, thus, vary in form from that regularly used by Paul Hastings to bill its clients for services rendered.

16 This translates into a voluntary waiver of \$89,100.00 in fees.

40. During the Fee Period, Paul Hastings assisted and advised the Trustee and the Genever Debtors on a regular basis regarding legal matters relating to these chapter 11 cases and the pursuit and recovery of estate assets for the benefit of the chapter 11 estates and their creditors. In addition, Paul Hastings prepared various motions, applications, proposed orders, and other pleadings submitted to the Court for consideration, and performed the necessary professional services that are described below and in the fee statements attached hereto and incorporated herein by reference.17

41. For ease of reference and transparency purposes, and at the request of the U.S. Trustee, Paul Hastings created the following separate Matter IDs for services in these

chapter 11 cases, including separate Matter IDs for the major adversary proceedings pending in these chapter 11 cases.

00001 General Chapter 11 Trustee Representation 00002 Asset Recovery Investigation and Litigation

17 The description of services in this Application is limited to those matters in which Paul Hastings provided five (5) or more hours of service during the Fee Period.

18 Not included as part of this Application.

42. Additionally, the Trustee and the Genever Debtors retained NPM as their local and conflicts counsel in order to provide services to the Trustee and the Genever Debtor's estates in a cost-effective manner. In particular, as detailed in the NPM retention application and related declarations, Paul Hastings and NPM have coordinated, and will continue to coordinate, each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. Among other things, during the Fee Period, the following matters were delegated to NPM:

- Assisting with filings and service of pleadings in the main chapter 11 case and related adversary proceedings; - Preparing supplemental motions for discovery under Bankruptcy Rule 2004 (including for discovery targets for which Paul Hastings is conflicted), conducting meet and confers with discovery targets, and reviewing documents produced in response to Rule 2004 subpoenas; - Assisting the Trustee on matters on which Paul Hastings is conflicted; - Preparing certain procedural motions, including motion to seal, motions to expedite, and motions to adjourn;

19 Not included as part of this Application.

20 Not included as part of this Application.

- Advising the Trustee and the Genever Debtors on matters related to local Connecticut rules; - Preparing monthly operating reports for the Genever Debtors; and - Performing a variety of case administration functions, including interacting with the Court and the clerks' office as needed, preparing certificates of service, coordinating logistics for hearings, and handling other case administration functions as they arise from time to time.

43. In addition, Paul Hastings has also delegated to NPM a number of important substantive matters -- including numerous adversary proceedings -- related to the Trustee's investigation and efforts to recover assets for the benefit of these estates.

44. Finally, Paul Hastings notes that, through this Application, it is not seeking allowance of fees or reimbursement of expenses with respect to the Civil RICO Adversary Proceeding. As the Court is aware, on February 15, 2024, the Trustee filed a complaint alleging that, since at least 2015, the Individual Debtor and various of his associates have operated a racketeering enterprise through an extensive worldwide network of shell companies with the goal of enriching the Individual Debtor, his family members, and his close associates, while concealing the true nature and extent of the Individual Debtor's wealth from his creditors and preventing them from being repaid. On December 9, 2024, the Bankruptcy Court entered an order staying the Civil RICO Adversary Proceeding pending resolution of the Trustee's First Omnibus Alter Ego Adversary Proceeding (as defined below). Paul Hastings intends to seek payment and allowance of its fees and expenses with respect to the Civil RICO Adversary Proceeding in the future. I. General Chapter 11 Trustee Representation (Matter ID 00001)

- i. Case Administration (Task Code B110) Fees: \$196,251.50 Total Hours: 178.20 - 45. During the Fee Period, Paul Hastings attorneys handled numerous case

administrative matters in connection with these chapter 11 cases, including (a) developing shortterm and long-term strategies for recovering assets for the benefit of these estates,

(b) maintaining a case calendar and task lists of open matters and work streams, (c) handling calls and correspondence with the U.S. Trustee and PAX regarding the background to, and the administration of, these chapter 11 cases, and (d) holding internal team meetings and calls to coordinate work streams.

ii. Pleadings Review (Task Code B113) Fees: \$99,693.50 Total Hours: 175.70

46. During the Fee Period, Paul Hastings attorneys and paraprofessionals reviewed and monitored the docket of these chapter 11 cases, the related adversary proceedings (of which there are now more than 300), and pending state court litigation, as well as reviewed pleadings filed therein, as necessary.

- iii. Court Hearings (Task Code B155) Fees: \$25,623.50 Total Hours: 22.90 - 47. During the Fee Period, Paul Hastings attorneys prepared for and attended

numerous hearings and status conferences. The following hearings were recorded under Matter

ID 00001, among others:

- the August 27, 2024 hearing on the Trustee's motion to amend mediation procedures to facilitate consensual pre-litigation mediation; - the October, 8 2024 hearing on (a) the Trustee's applications to retain Winne, Banta, Basraliam & Kahn, P.C. ("WBBK"), as New Jersey real estate counsel, and Chryssafinis & Polyviou LLC ("CP Law"), as Cypriot counsel, (b) Genever US's motion to amend retention order of Sotheby's International Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 30 of 879

Realty ("Sotheby's"), and (c) the Trustee's motion to limit notice of Rule 9019 motions regarding mediated or avoidance claim settlements; and

the October 15, 2024 status conference regarding the First Omnibus Alter Ego Adversary Proceeding and the Civil RICO Adversary Proceeding.

48. In addition, as detailed below, attendance at several other hearings during the Fee Period were recorded under the applicable Matter ID. That said, general hearing preparation (including agendas) for the various hearings scheduled in August, September, October, and November 2024 was also recorded under Matter ID 00001.

iv. Fee / Employment Applications for Paul Hastings (Task Code B160) Fees: \$75,461.50 Total Hours: 56.80

49. During the Fee Period, in connection with Paul Hastings' retention, Paul Hastings attorneys prepared and submitted a supplemental declaration with respect to the Trustee's and Paul Hastings' disinterestedness [Docket No. 3707] and continued to research possible connections between the Trustee and Paul Hastings, on the one hand, and parties in interest in these chapter 11 cases, on the other hand. In addition, Paul Hastings attorneys prepared (a) the Sixth Interim Fee Application [Docket No. 3700] (which the Court granted on November 13, 2024 [Docket No. 3814]), and (b) Paul Hastings' monthly fee statements for services rendered in April, May, June, July, August, and September 2024. Paul Hastings also corresponded and engaged in discussions with the U.S. Trustee to address questions regarding the above fee and expense reimbursement requests. Among other things, Paul Hastings consensually resolved the U.S. Trustee's informal comments to the Sixth Interim Fee Application.

- v. Fee / Employment Applications for Other Professionals (Task Code B165) Fees: \$188,464.00 Total Hours: 127.70 - 50. During the Fee Period, Paul Hastings attorneys prepared the Trustee's

applications to retain, among others:

- Compass, Inc. as real estate broker with respect to the sale of the Taconic Property, which application was filed on August 23, 2024 [Main Case Docket No. 3450] and granted on September 4, 2024 [Docket No. 3504]. - WBBK as New Jersey real estate counsel, which application was filed on September 16, 2024 [Docket No. 3534] and granted on October 9, 2024 [Docket No. 3652]. - CP Law as Cypriot law counsel, which application was filed on September 23, 2024 [Docket No. 3569] and granted on October 9, 2024 [Docket No. 3653]. - ENSafrida ("ENS") as attorneys in the Republic of Mauritius, which application was filed on October 2, 2024 [Docket No. 3625] (and granted on October 22, 2024, Main Case Docket No. 3740), - Patrice Doger de Speville, Senior Counsel, and William de Robillard, Of Counsel (the "Mauritius Barristers," and together with ENS, the "Mauritius Counsel"), which application was filed on October 7, 2024 [Docket No. 3646] and granted on October 22, 2024 [Docket No. 3741]. - James Morgan, King's Counsel as barrister in the BVI under the instruction of Harneys Westwood & Riegels LP ("Harneys") (the "BVI Barrister," and together with Harneys, the "BVI Counsel"), which application was filed on October 15, 2024 [Docket No. 3701] and granted on November 5, 2024 [Docket No. 3784]. - Peter Shaw, King's Counsel as barrister in the United Kingdom (together with Paul Wright, the "UK Barristers"), which application was filed on November 25, 2024 [Main Case Docket No. 3849] and granted on December 11, 2024 [Docket No. 3872]. - Compass New Jersey, LLC as real estate broker for the sale of the Mahwah Mansion, which application was filed on November 26, 2024 [Docket No. 3855] and granted on December 11, 2024 [Docket No. 3873]. - Kobre & Kim, as special counsel in the UAE, which application was filed on December 17, 2024 (i.e., after the Fee Period) [Docket No. 3911] and granted on January 10, 2025 [Docket No. 3941]. - 51. In addition, Paul Hastings attorneys also prepared Genever US's motion to amend

order authorizing retention of Sotheby's as real estate broker and sales agent, which motion was

filed on September 18, 2024 [Docket No. 3551] and granted on October 9, 2024 [Docket No.

3660]. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 32 of 879

52. In addition, during the Fee Period, Paul Hastings attorneys handled various other fee-related issues, including (a) assisting UK Barristers, Eisner Advisory Group LLC ("Eisner"), Kroll, LLC ("Kroll"), Pallas Partners LLP ("Pallas"), O'Sullivan McCormack Jensen & Bliss PC ("OMJB"), Prager Dreifuss AG ("Prager") with preparing their interim fee applications [Docket Nos. 3692, 3693, 3694, 3697, 3698, and 3699], (b) reviewing the interim fee applications of NPM, (c) reviewing various fee statements and assisting Prager with preparing its monthly fee statements [Docket Nos. 3393, 3394, 3628, 3780, and 3863].

- vi. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$9,153.25 Total Hours: 9.90 - 53. During the Fee Period, Paul Hastings attorneys traveled to Bridgeport,

Connecticut, for the September 11, 2024, September 24, 2024, and October 15, 2024 hearings.

- vii. Business Operations (Task Code B210) Fees: 48,448.00\$ Total Hours: 37.50 - 54. During the Fee Period, Paul Hastings attorneys assisted the Trustee with various

matters related to the operation of these chapter 11 estates, including handling wire transfers.

- viii. Financial Reports (Monthly Operating Reports) (Task Code B211) Fees: \$20,195.00 Total Hours: 15.20 - 55. During the Fee Period, Paul Hastings attorneys prepared the monthly operating reports in the Individual Debtor's chapter 11 case. In the interest of minimizing costs, the monthly operating reports for the Genever Debtors were prepared by NPM, and any time spent by Paul Hastings attorneys reviewing and commenting such reports was recorded under Matter

ID 00010 (for Genever (US)) and 00011 (for Genever (BVI)). II. Asset Recovery Investigation and Litigation (Matter ID 00002)

i. Court Hearings (Task Code B155) Fees: \$17,086.50 Total Hours: 9.50

56. During the Fee Period, Paul Hastings attorneys prepared for numerous hearings and status conferences regarding the Trustee's investigation and related litigation. As detailed further below, attendance at these various hearings was generally recorded under the Matter ID for the applicable adversary proceeding. The following hearings were recorded under Matter ID 00002, among others:

- the November 5, 2024 hearing on the Trustee's 17th supplemental omnibus Rule 2004 motion; - the November 6, 2024 hearing on G Club Operations LLC's motion to quash subpoena; and - the November 18, 2024 hearing on G Club Operations LLC's motion to quash subpoena (continued from November 6, 2024). - ii. General Litigation (Task Code B191) Fees: \$113,004.00 Total Hours: 92.40

57. During the Fee Period, Paul Hastings attorneys continued to (a) analyze and coordinate service on international defendants in various adversary proceedings, (b) conduct research on pertinent legal questions relating to issues in the Trustee's current litigation and investigations, analyze enforcement of judgment in foreign jurisdictions, (c) prepare pleadings to recover additional assets for the estate, and (d) monitor and manage various appeals to the District Court and Second Circuit.

58. Paul Hastings attorneys also assisted NPM in preparing the Trustee's motion to extend deadline to file avoidance actions to February 15, 2025 [Docket No. 3329] (the "Further Tolling Motion"). The Trustee filed the Further Tolling Motion because, despite the diligent efforts of the Trustee and his professionals, and the significant and important progress and Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 34 of 879

success he has already made, the enormity of the Trustee's task and the constant obstruction he faced, coupled with the delay caused by the Criminal Trial which also revealed important information the Trustee had not learned in discovery, rendered it impossible for him to complete his investigation and bring all available causes of action prior to August 15, 2024 (i.e., the extended deadline pursuant to the Court's order on February 15, 2024). The Court granted the Trustee's motion on August 14, 2024.

iii. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$12,025.50 Total Hours: 13.30

59. During the Fee Period, Paul Hastings attorneys traveled to New York for deposition, meeting with discovery targets and other investigation related matters.

iv. Investigations (Task Code B261) Fees: \$644,877.00 Total Hours: 490.20

60. During the Fee Period, Paul Hastings attorneys continued to handle the Trustee's investigation to identify potential assets of the Individual Debtor's estate. Given the corporate maze of shell companies set up by the Individual Debtor, including hundreds of companies purportedly owned by his close family members, business associates, and employees, this investigation has necessarily been extensive and time intensive.

61. As part of this investigation, Paul Hastings attorneys (a) analyzed documents produced in response to Rule 2004 subpoenas,21 (b) prepared Rule 2004 motion and discovery request, (c) engaged in meet and confer sessions with the targets of the Rule 2004 discovery, (d) identified additional entities for further investigation, (e) conducted numerous calls and meetings with the Trustee's forensic accountant (Kroll) to advance the Trustee's investigation

21 As further detailed below, in the interest of minimizing costs, Paul Hastings utilized UnitedLex Corporation ("UnitedLex") to conduct, among other things, first-round review of documents produced in the Trustee's investigation. UnitedLex specializes in discovery services, including document processing, storage, review services, and distribution. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 35 of 879

concerning potential estate claims, (f) analyzed potential claims against the Individual Debtor and his affiliated entities, (g) held internal conferences to discuss and strategize issues relating to the Trustee's ongoing investigation, (h) prepared for and conducted numerous Rule 2004 depositions, and (i) analyzed exhibits and testimony from the Criminal Trial.

62. Paul Hastings attorneys also continued to assist NPM in preparing supplemental motions under Bankruptcy Rule 2004 seeking discovery from various individuals and entities associated with the Individual Debtor, including (a) the sixteenth supplemental motion filed on August 13, 2024 [Docket No. 3398],22 which was granted by the Court on August 26, 2024 [Docket No. 3454], (b) the seventeenth supplemental motion filed on September 30, 2024 [Docket No. 3594], which was granted by the Court on November 15, 2024 [Docket No. 3823], (c) the Trustee's reply in support of the seventeenth supplemental motion [Docket No. 3767], (d) the Trustee's Rule 2004 motion to authorize examination of Schulman Bhattacharya, LLC (longtime personal counsel to the Individual Debtor and Debtor-related shell entities) [Docket No. 3758], which was granted by the Court on November 13, 2024 [Docket No. 3807], and (e) the Trustee's objection to G Club Operations LLC's motion to quash the Trustee's rule 2004 subpoena [Docket No. 3778]. The motion to quash was denied by the Court on November 18, 2024 [Docket No. 3835].

63. Furthermore, during the Fee Period, Paul Hastings attorneys continued to communicate with confidential informants, who provided valuable insight into the Individual Debtor's business operations.23

22 The supplemental Rule 2004 motions were filed by NPM because Paul Hastings was conflicted as to some of the discovery targets. To the extent Paul Hastings did not have a conflict, it assisted NPM in preparing the supplemental motion.

23 In light of the Individual Debtor's well-documented social media campaign against the Trustee, Paul Hastings attorneys, and creditors in these chapter 11 cases, the time entries attached to this Application have been redacted to remove the names of these informants. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 36 of 879

64. As noted in Paul Hastings' prior fee applications, much of the Trustee's investigation also required the expertise of Paul Hastings' Mandarin-speaking attorney in order to analyze thousands Mandarin-language documents (including WhatsApp, text messages, and videos). This work required not only Mandarin language skills but an understanding of the legal significance of these documents, which an outside translation service would not be able to provide. Paul Hastings' Mandarin-speaking attorney has also been critical for the Trustee to communicate with the numerous Mandarin-speaking informants that have reached out to the Trustee during the course of these chapter 11 cases.

65. To date, the Trustee's investigation (including as a result of discovery under Rule 2004, information provided by confidential informants, and corporate documents received from BVI registered agents) uncovered numerous assets that the Trustee believes are property of the Individual Debtor's estate, which the Trustee is seeking to recover for the benefit of the estate. In fact, as detailed further below, during the Fee Period, the Trustee continued to prosecute several adversary proceedings to recover such assets.

66. Unfortunately, as the Court is well aware, the Trustee's investigation continued to face vigorous opposition, at every turn, not only from the Individual Debtor, but also many of the targets of the Trustee's investigation (i.e., the Individual Debtor's close family members, business associates, and employees), necessitating further motion practice.

i. General Litigation (Task Code B191) Fees: \$39,987.50 Total Hours: 32.80

67. During the Fee Period, Paul Hastings attorneys assisted the Trustee on various litigation-related matters (other than the adversary proceedings pending in these chapter 11 Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 37 of 879

cases), including the Criminal Case. Among other things, Paul Hastings attorneys continued to monitor the Criminal Case and analyzed pleadings filed in the Criminal Case.

68. As the Court may recall, on May 3, 2024, the Individual Debtor's co-defendant and chief of staff Yvette Wang pleaded guilty to one count of conspiracy to commit wire fraud and one count of conspiracy to commit money laundering. The statutory maximum term of imprisonment on the two counts is ten years. On January 6, 2025, the SDNY Court held a sentencing hearing with respect to Yvette Wang and imposed a sentence of ten years in prison as to Wang, finding Yvette Wang to be an "integral part of the conspiracy and knew what she was doing was illegal." Earlier, on July 16, 2024, a unanimous jury had found the Individual Debtor guilty on nine of the 12 charges, including multiple conspiracy charges and multiple wire fraud and securities fraud charges. The Individual Debtor's sentencing date remains pending.

69. In addition, during the Fee Period, Paul Hastings attorneys also prepared and filed suggestions of bankruptcy in state court litigations and analyzed legal issues concerning the automatic stay in connection with the state court litigations.

i. Asset Disposition (Task Code B130) Fees: \$8,747.00 Total Hours: 7.70

70. During the Fee Period, Paul Hastings attorneys, in coordination with NPM, (a) handled the transfer of title of four motorcycles from their purported owner Defeng Cao (longterm boyfriend of Mei Guo) to the Trustee, upon the Bankruptcy Court granting the Trustee's motion for judgment on the pleadings in the Cao Adversary Proceeding (as defined below) and finding that the four motorcycles are beneficially owned by the Debtor and therefore are property of the estate, (b) handled transfer of title of a Lexus vehicle found at the Taconic Property which Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 38 of 879

was nominally held by Yun Jing (a known associate of the Debtor) to the Trustee, and (c) discussed issues relating to potential auction of such vehicles.

ii. Sale of Real Estate (Task Code B131) Fees: \$79,885.50 Total Hours:

71. During the Fee Period, Paul Hastings attorneys, in coordination with NPM and in connection with the sale of the Taconic Property, (a) prepared the Trustee's application to employ Compass, Inc. as real estate broker for the sale of the Taconic Property [Docket No. 3450] and motion to expedite the hearing on the motion, which retention application was granted by the Bankruptcy Court on September 4, 2024 [Docket No. 3504], (b) prepared the Trustee's motion to authorize and approve the sale of the Taconic Property [Docket No. 3592] filed on September 30, 2024, which the Court granted on October 15, 2024 [Docket No. 3690], (c) worked on issues relating to the bidding process, (d) corresponded and negotiated with the bidders, (d) analyzed legal issues relating to the sale of the Taconic Property and terms of the sale contract, and (e) conducted inspections and walkthrough at the Taconic Property.

72. Furthermore, during the Fee Period, Paul Hastings attorneys, in coordination with NPM and in connection with the sale of the Mahwah Mansion, (a) prepared the Trustee's motion for authorization to sell Mahwah Mansion and its contents [Adv. Proc. No. 23-05017, Docket No. 134], which was granted by the Bankruptcy Court on October 29, 2024 [Adv. Proc. No. 23- 05017, Docket No. 142], (b) conferred with counsel to Taurus Fund regarding the proposed order to sell the Mahwah Mansion and its contents, (c) analyzed legal issues relating to the sale process of the Mahwah Mansion, (d) interviewed brokers and held conference calls regarding the marketing plans for the Mahwah Mansion, and (e) prepared and filed the Trustee's application seeking authorization to employ Compass New Jersey, LLC as real estate broker for sale of the Mahwah Mansion [Main Case Docket No. 3855]. Upon a hearing held on December 10, 2024, Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 39 of 879

on December 11, 2024, the Bankruptcy Court granted the Trustee's application to retain Compass New Jersey, LLC [Main Case Docket No. 3873].

iii. Court Hearings (Task Code B155) Fees: \$20,717.00 Total Hours: 11.00

73. During the Fee Period, Paul Hastings attorneys prepared for and attended hearings and status conferences relating to the Trustee's motion for authorization to sell the Mahwah Mansion and its contents. On October 29, 2024, the Bankruptcy Court entered an order authorizing the Trustee to sell the Mahwah Mansion and its contents, subject to entry of further orders.

i. Tax Issues (Task Code B240) Fees: \$20,499.00 Total Hours: 11.30

74. During the Fee Period, Paul Hastings attorneys continued to confer with the

Trustee's tax advisors (i.e., Eisner Advisory Group LLC, "EA Group") regarding the preparation of tax filings for the Debtors. Among other things, Paul Hastings attorneys held several conference calls with EA Group employees to address their questions regarding various transactions during these chapter 11 cases.

i. Sale of Real Estate (Task Code B131) Fees: \$15,510.00 Total Hours: 8.10

75. During the Fee Period, in anticipation of completing the remediation and cleaning work at the Sherry Netherland Apartment, Paul Hastings attorneys engaged with Sotheby's to discuss marketing and sale of the Sherry Netherland Apartment. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 40 of 879 ii. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$1,110.00 Total Hours: 1.20

76. During the Fee Period, Paul Hastings attorneys traveled to the Sherry Netherland Apartment to discuss and oversee the remediation and cleaning projects.

iii. Business Operations (Task Code B210) Fees: \$19,795.00 Total Hours: 11.70

77. During the Fee Period, Paul Hastings attorneys analyzed various operational

matters with respect to Genever (US), including, most notably, as it relates to the remediation and cleaning work for the Sherry Netherland Apartment. Among other things, Paul Hastings attorneys (a) worked closely with the architect (Acheson Doyle) regarding progress of the remediation and cleaning projects, (b) prepared the monthly status reports in accordance with the Court's order, dated September 19, 2023 [Docket No. 2213]. As indicated in its latest status report [Docket No. 3794], the remediation project and the cleaning project were substantially completed in August 2024, and the Trustee has begun marketing the Sherry Netherland Apartment in mid-September 2024.

i. Security Document Analysis (Task Code B231) Fees: \$10,345.50 Total Hours: 6.20

78. During the Fee Period, Paul Hastings attorneys, in coordination with the Trustee's BVI counsel, Harneys, analyzed legal issues relating to the release of duplicate lien charge

against Genever BVI.

i. Court Hearings (Task Code B155) Fees: \$126,681.50 Total Hours: 93.10

79. During the Fee Period, Paul Hastings attorneys prepared for and handled hearings and status conferences recorded under this matter number in connection with (a) Trustee's Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 41 of 879

request to determine applicable deadlines to further proceedings in the Mahwah Adversary Proceeding (as defined below) [Docket No. 114 in Adv. Proc. No. 23-05017], and (b) the Trustee's motion for order authorizing sale of the Mahwah Mansion and its contents [Docket No. 134 in Adv. Proc. No. 23-05017], (c) the Trustee's motion for summary judgment [Docket No. 124 in Adv. Proc. No. 23-05017]. Preparation for these hearings included (a) analyzing legal authority, (b) preparing argument outline, and (c) preparing a 65-page demonstrative showcasing and summarizing key aspects of the Trustee's voluminous evidentiary record in support of the motion for summary judgment.

ii. General Litigation (Task Code B191) Fees: \$530,625.00 Total Hours: 397.20

80. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC [Adv. Proc. No. 23-05017] (the "Mahwah Adversary Proceeding"). In the Mahwah Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the Debtor is the equitable owner of the 50,000 square foot Mahwah Mansion, (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to Mahwah Mansion), and (c) that Taurus Fund, LLC is an alter ego of the Individual Debtor.

81. Following the conclusion of the Individual Debtor's Criminal Trial, Paul Hastings attorneys prepared and filed on August 1, 2024 the Trustee's notice of resumption of the Mahwah Adversary Proceeding [Docket No. 110 in Adv. Proc. No. 23-05017], which was stayed pursuant to the Court's order on February 2, 2024 [Docket No. 102 in Adv. Proc. No. 23-05017].

82. On September 11, 2024, Paul Hastings attorneys prepared and filed the Trustee's motion for summary judgment [Docket Nos. 124, 125 in Adv. Proc. No. 23-05017], which Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 42 of 879

contains a voluminous evidentiary record supporting the Trustee's motion including a statement of undisputed facts containing 56 paragraphs and citing to 279 exhibits and the testimony of more than 15 witnesses, either by way of deposition transcript or in-court testimony. During the Fee Period, Paul Hastings attorneys also (a) analyzed the defendants' opposition to the Trustee's motion for summary judgment and related legal issues, (b) prepared and filed the Trustee's reply [Docket Nos. 146, 147 in Adv. Proc. No. 23-05017], and (c) prepared for and handled the hearing on the Trustee's motion for summary judgment on November 19, 2024.

83. Furthermore, during the Fee Period, Paul Hastings attorneys, in coordination with NPM, also (a) analyzed and strategized next steps in adversary proceeding, (b) prepared the Trustee's reply to the defendants' response to the Trustee's emergency motion to approve estate funding to maintain Mahwah Mansion [Docket No. 113 in Adv. Proc. No. 23-05017], (c) prepared stipulation with certain third party vendor regarding its state court mechanics' lien action, (d) analyzed the defendants' motion to withdraw the reference and prepared the Trustee's objection filed on August 30, 2024 [Docket No. 10 in Case No. 3:24-mc-00085], (e) prepared the Trustee's request for status conference [Docket No. 114 in Adv. Proc. No. 23-05017], and (f) prepared the Trustee's motion to exceed the page limit with respect to the Trustee's forthcoming summary judgment motion [Docket No. 122 in Adv. Proc. No. 23-05017].

84. In addition, as the Court may recall, following the Individual Debtor's conviction, Taurus Fund ceased to pay expenses related to maintenance of the Mahwah Mansion. During the Fee Period, Paul Hastings attorneys continued to handle issues in connection with Taurus Fund ceasing to pay such expenses, including seeking (and obtaining) authorization to fund such expenses from the Individual Debtor's estate and filing motion to increase cap on funding of expenses of Mahwah Mansion [Docket No. 3650]. Among other things, the Trustee obtained Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 43 of 879

Court authorization to fund these security and maintenance costs on August 15, 2024 [Docket No. 3422] and following a hearing on October 15, 2024 on the Trustee's motion to increase the cap on funding expenses of Mahwah Mansion, the Court entered an order granting the Trustee's motion to increase such cap [Docket No. 3689].

i. General Litigation (Task Code B191) Fees: \$4,723.00 Total Hours: 3.60

85. During the Fee Period, Paul Hastings attorneys continued to prosecute the appeals relating to adversary proceeding [Adv. Proc. No. 23-05013] (the "HCHK Adversary Proceeding"). In the HCHK Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) HCHK Technologies, Inc. ("HCHK Technologies"), HCHK Property Management, Inc. ("HCHK Property"), Lexington Property and Staffing, Inc. ("Lexington Property," and, together with HCHK Technologies and HCHK Property, the "HCHK Entities") are alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets. In addition, the complaint sought an injunction against the commencement or continuation of the assignment proceedings commenced with respect to the HCHK Entities in New York state court (the "Assignment Proceedings"). In connection with the HCHK Adversary Proceeding, the Trustee also requested and obtained a temporary restraining order as it relates to the commencement or continuation of the Assignment Proceeding [Docket No. 18 in Adv. Proc. No. 23-05013]. On June 14, 2024, the Court granted the Trustee's motion for default judgment, holding, among other things, that the HCHK Entities are the alter egos of the Individual Debtor and directing that the property of the HCHK Entities be turned over to the estate [Docket No. 290 in Adv. Proc. No. 23-05013]. As a result of this ruling, among other things, over \$38 million of the HCHK Entities' funds (previously transferred into accounts Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 44 of 879

controlled by the Trustee pursuant to the settlement with the Assignee) are now property of the estate.

86. On September 30, 2024, clerk of the District Court entered a judgment, dismissing with prejudice the proposed intervenors' appeal of this Court's intervention order pursuant to a stipulation by the parties. In addition, in light of the withdrawal of counsel for appellants and subsequent failure of HCHK entities (including HCHK BVI) to secure successor counsel, on October 24, 2024, the District Court entered an order of dismissal, dismissing the consolidated appeal by HCHK Entities as well as Holy City Hong Kong Ventures, Ltd ("HCHK BVI") of this Court's memorandum of decision and order denying motion to set aside default.

87. Among other things, during the Fee Period, Paul Hastings attorneys analyzed issues relating to the withdrawal of appellants' counsel and prepared for the hearing on appellants counsel's motion to withdrawal.

88. Moreover, during the Fee Period, Paul Hastings attorneys also, with assistance from UnitedLex, reviewed and analyzed contents of devices belonging to HCHK Entities.

ii. Business Operations (Task Code B210) Fees: \$3,514.50 Total Hours: 3.60

89. During the Fee Period, Paul Hastings attorneys continued to work with the Assignee's counsel to handle administrative matters relating to HCHK Entities, including handling correspondences from HCHK Entities' former employees and issues relating to payroll and payment of invoices

i. General Litigation (Task Code B191) Fees: \$39,123.00 Total Hours: 27.20

90. During the Fee Period, Paul Hastings attorneys continued to assist NPM in prosecuting appeals relating to the adversary proceeding [Adv. Proc. No. 22-05008] (the "Mei Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 45 of 879

Guo Adversary Proceeding"). In the Mei Guo Adversary Proceeding, the Trustee seeks (a) an order declaring that the proceeds (the "Bombardier Proceeds") from the sale of the Individual Debtor's private Bombardier jet (the "Bombardier") are property of the estate, (b) an order that Mei Guo surrender the Bombardier Proceeds or the value thereof to the Trustee because she received the Bombardier Proceeds as an unauthorized postpetition transfer avoidable under section 549 of the Bankruptcy Code, (c) an order that Mei Guo surrender to the Trustee the value of the Individual Debtor's shell company Anton Development Limited ("Anton Development") at the time the company was transferred to her on June 27, 2017 (upon which date Anton Development was title holder to the Bombardier) pursuant to a transaction avoidable as an actual fraudulent transfer, and (d) an order declaring that a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate. On April 3, 2024, the Court granted, in part, the Trustee's motion for summary judgment, holding, among other things, that the Individual Debtor beneficially owned the Bombardier and, hence, beneficially owns the Bombardier proceeds and directing Mei Guo to turn over to the estate the Bombardier proceeds [Adv. Proc. No. 22-05008, Docket No. 126] (the "Mei Guo Summary Judgment Order"). On April 17, 2024, Mei Guo appealed this decision to the District Court.

91. Among other things, during the Fee Period, Paul Hastings attorneys reviewed and analyzed the Trustee's appellate brief with respect to Mei Guo's appeal of the foregoing summary judgment ruling, which was filed on September 13, 2024. On January 21, 2025 (i.e., after the Fee Period), the District Court affirmed this Court's Mei Guo Summary Judgment Order.

92. In addition, Paul Hastings attorneys analyzed issues relating to Mei Guo's violation of the preliminary injunction order issued by this Court in the Mei Guo Adversary Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 46 of 879

Proceeding and prepared the Trustee's motion to enforce the preliminary injunction, which was filed on December 20, 2024 [Docket No. 140 in Adv. Proc. No. 23-05008]. XI. HK USA Adversary Proceeding (Matter ID 00017)

i. General Litigation (Task Code B191) Fees: \$14,463.50 Total Hours: 8.10

93. During the Fee Period, Paul Hastings attorneys, in coordination with NPM,

continued to prosecute appeals relating to the HK USA Adversary Proceeding. On August 23, 2024, the District Court affirmed this Court's orders granting the Trustee's motion for summary judgment in which this Court determined that the Individual Debtor was the beneficial owner of the Lady May yacht and that HK USA was the Individual Debtor's alter ego [Docket No. 60 in Case No. 3:23-cv-00458-KAD]. Clerk of the District Court entered judgment in favor of the Trustee on September 5, 2024 [Docket No. 61 in Case No. 3:23-cv-00458-KAD].

94. Among other things, during the Fee Period, Paul Hastings attorneys (a) reviewed and analyzed legal issues relating to the appellate decision, (b) held internal discussions to strategize and analyze case materials, and (c) in coordination with NPM, prepared and filed the Trustee's appellate brief to the United States Court of Appeals for the Second Circuit from the District Court's judgment affirming this Court's orders of contempt and sanctions [Docket No. 33 in Case No. 24-1271]. XII. Greenwich Land Adversary (Matter ID 00020)

i. Sale of Real Estate (Task Code B131) Fees: \$19,750.00 Total Hours: 10.00

95. During the Fee Period, Paul Hastings attorneys, in coordination with NPM, handled various issues relating to the sale of the Taconic Property, including participating in negotiation for the sale, corresponding with counsels to various bidders, reviewing and analyzing sale documents, and resolving issues as to insurance for the Taconic Property. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 47 of 879 ii. General Litigation (Task Code B191) Fees: \$50,077.50 Total Hours: 27.50

96. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against Greenwich Land and Hing Chi Ngok [Adv. Proc. No. 23-05005] (the "Greenwich Land Adversary Proceeding"). In the Greenwich Land Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Greenwich Land is an alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Greenwich Land. On July 3, 2024, the Court granted the Trustee's motion for summary judgment, holding, among other things, that Greenwich Land is an alter ego of the Individual Debtor and directing that the property of Greenwich Land be turned over to the estate. As a result of this ruling, among other things, the Debtor's multi-million-dollar mansion located at 373 Taconic Road, Greenwich, Connecticut is now property of the estate.

97. During the Fee Period, Paul Hastings attorneys, in coordination with NPM, analyzed issues relating to the defendants' motion to stay pending appeal, which motion was resolved upon the Court's entering of the consent order resolving defendants' motion [Docket No. 166 in Adv. Proc. No. 23-05005], and on September 30, 2024 prepared and filed the Trustee's motion to sell the Taconic Property for a purchase price of \$6.9 million [Docket No. 3592]. The Trustee subsequently filed a notice to the Court on October 14, 2024 regarding a higher and better offer to purchase the Taconic Property for \$7.25 million [Docket No. 3682]. Paul Hastings attorneys also (a) prepared for and attended the hearing on October 15, 2024 regarding the Trustee's motion to sell the Taconic Property, (b) handled issues regarding insurance for the Taconic Property, and (c) conducted inspections at the Taconic Property in connection with its sale. On October 22, 2024, in coordination with NPM. Paul Hastings Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 48 of 879

attorneys prepared and filed the Trustee's report of sale regarding the Taconic Property where the property was sold for \$7.25 million [Docket No. 3743].

98. In addition, Paul Hastings attorneys, in coordination with NPM, continued to handle the appeals in the District Court as to the Greenwich Land Adversary Proceeding. During the Fee Period, Paul Hastings prepared counter-designations in connection with Greenwich Land and Ms. Ngok's appeal as to the Bankruptcy Court's order Trustee's motion for summary judgment, and in connection with NPM, prepared and filed the Trustee's appellee brief on December 30, 2024 [Docket No. 19 in Case No. 3:24-cv-01185]. Furthermore, on January 2, 2025, the District Court entered a Memorandum of Decision denying Greenwich Land and Ms. Ngok's motion to withdraw the reference [Docket No. 169 in Adv. Proc. No. 23-05005]. XIII. Lamp Capital Adversary Proceeding (Matter ID 00024)

i. General Litigation (Task Code B191) Fees: \$113,079.50 Total Hours: 89.90

99. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against Lamp Capital LLC and certain other defendants [Adv. Proc. No. 23-05023] (the "Lamp Capital Adversary Proceeding"). In the Lamp Capital Adversary Proceeding, the Trustee seeks determinations that, among other things, Lamp Capital, Hudson Diamond, and Leading Shine are the Individual Debtor's alter egos and that the Individual Debtor equitably owns these alter ego defendants and their assets. In February 2024, the Bankruptcy Court granted the Trustee's motion for entry of default judgment on his claims that Lamp Capital, another allegedly independent company nominally owned by Qiang Guo (i.e., the Debtor's son) that was used by the Debtor as a funding vehicle, was an alter ego of and equitably owned by the Debtor [Docket No. 63 in Adv. Proc. No. 23-05023]. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 49 of 879

100. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's motion for summary judgment as to Trustee's claims against Hudson Diamond and Leading Shine [Docket Nos. 97, 98 in Adv. Proc. No. 23-05023], as well as the Trustee's reply to the defendant's opposition to the summary judgment motion [Docket No. 117 in Adv. Proc. No. 23- 05023]. A hearing on the Trustee's summary judgment motion was held on December 10, 2024 (i.e., after the Fee Period), and the matter is currently under advisement by this Court. XIV. Ace Decade Adversary Proceeding (Matter ID 00026)

i. General Litigation (Task Code B191) Fees: \$58,704.50 Total Hours: 37.70

101. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against Ace Decade, Yvette Wang, and Rui Hao [Adv. Proc. No. 23-05028] (the "Ace Decade Adversary Proceeding"). In the Ace Decade Adversary Proceeding, the Trustee seeks declarations that the transfer of the Ace Decade share by defendant Wang to defendant Hao is void in light of this Court's prior ruling that the Trustee beneficially owns the Ace Decade share.

102. During the Fee Period, on September 10, 2024, Paul Hastings attorneys handled hearing on the Trustee's motion for entry of default judgment as against defendant Rui Hao [Docket No. 75 in Adv. Proc. No. 23-05028], which the Court granted on September 12, 2024.

103. In addition to the foregoing, during this adversary proceeding, the Trustee learned that, in June 2024, Defendant Hao commenced liquidation proceedings in the British Virgin Islands ("BVI") with respect to Ace Decade and Dawn State. Accordingly, Paul Hastings was also required to address the BVI liquidation proceedings as part of the Trustee's continuing efforts to obtain ownership and control over Ace Decade and Dawn State. To that end, during the Fee Period, Paul Hastings attorney handled a variety of issues, in coordination with the Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 50 of 879

Trustee's BVI counsel, relating to the liquidation proceedings with respect to Ace Decade. Among other things, Paul Hastings attorneys (a) coordinated with the Trustee's BVI counsel (Harneys) to address the appointment of the purported BVI joint liquidator and seek relief in the BVI court to rectify the member register for Ace Decade and Dawn State so as to reflect the Trustee is the true holder of the shares in Ace Decade and Dawn State, (b) prepared and reviewed the Trustee's affidavit filed with the BVI court, (c) analyzed legal issues relating to Defendant Rui Hao's continuing violation of the automatic stay, (d) continued to confer with the purported BVI joint liquidators regarding the Trustee's ownership of the Ace Decade and Dawn State shares, and (e) held internal conferences to discuss and strategize.

104. In addition, in coordination with NPM, Paul Hastings attorneys also analyzed issues relating to enforcing the default judgment entered against Yvette Wang. On January 31, 2025 (i.e., after the Fee Period), the Trustee filed his Ex Parte Application for Pre-Judgment Remedy Against Defendant Yvette Wang [Docket No. 86 in Adv. Proc. No. 23-05028], which the Court granted on February 4, 2025 [Docket No. 89 in Adv. Proc. No. 23-05028]. XV. Defeng Cao Adversary Proceeding (Matter ID 00027)

i. General Litigation (Task Code B191) Fees: \$40,653.00 Total Hours: 26.40

105. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Defeng Cao (the long-term boyfriend of the Debtor's daughter) [Adv. Proc. No. 24-05001] (the "Defeng Cao Adversary Proceeding"). In the Defeng Cao Adversary Proceeding, the Trustee seeks to recover six separate vehicles—three Harley Davidsons and one BMW motorcycle, as well as one Land Rover Defender and one Dodge Ram Pickup Truck which, while nominally held by the defendant, were fraudulently transferred to the defendant, or alternatively, are equitably owned by the Individual Debtor.

106. On September 9, 2024, the Court granted the Trustee's motion for judgment on the pleadings, holding that the motorcycles are property of the estate and requiring Mr. Cao to turn them over to the estate. During the Fee Period, Paul Hastings attorneys handled the transfer of title of the four motorcycles to the Trustee and analyzed and strategized next steps in litigation in this adversary proceeding, including discussing settlement proposal with the defendant. XVI. Omnibus Alter Ego Adversary Proceeding (Matter ID 00028)

i. General Litigation (Task Code B191) Fees: \$524,561.00 Total Hours: 400.80

107. During the Fee Period, Paul Hastings attorneys continued to prosecute the adversary proceeding commenced by the Trustee against more than forty entities—each nominally owned by a family member or associate of the Individual Debtor)—seeking rulings that such entities are alter egos of the Individual Debtor and/or their assets are beneficially owned by the Individual Debtor, such that their assets are property of the estate [Adv. Proc. No. 24-05249] (the "First Omnibus Alter Ego Adversary Proceeding").

108. During the Fee Period, Paul Hastings attorneys, in coordination with NPM, handled the hearing on the Trustee's motion for entry of default judgment against the Individual Debtor's son, i.e., Qiang Guo, and K Legacy. On September 12, 2024, the Trustee obtained entries of default as against K Legacy and Qiang Guo, pursuant to which the Court held, among other things, that the ownership interests in K Legacy and the assets of K Legacy, including a luxury apartment in London, are property of the estate. In addition to obtaining a default judgment against K Legacy and the Debtor's son, during the Fee Period the Trustee also commenced and continued to prosecute proceedings in the BVI, i.e., the jurisdiction where K Legacy is incorporated, to, among other things, seek rulings that the Trustee beneficially owns K Legacy and the London apartment. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 52 of 879

109. Furthermore, upon request of the Trustee, on September 13, 2024, the Clerk of the Court entered default against more than 15 defendants in the First Omnibus Alter Ego Adversary Proceeding [Adv. Proc. Docket No. 79].

110. In addition, during the Fee Period, in connection with the First Omnibus Alter Ego Adversary Proceeding, Paul Hastings attorneys (a) analyzed motions to dismiss the original complaint and later the amended complaint in the adversary proceeding filed by certain defendants (the "Moving Defendants"), (b) analyzed legal issues in connection with severing the defendants against whom the Clerk of the Court entered default from this adversary proceeding, (c) prepared amended complaint and the Trustee's response to various defendants' motions to dismiss, (d) analyzed and researched legal issues in connection with the amended complaint, and (e) held internal conferences to discuss strategy. Paul Hastings attorneys, in coordination with NPM, handled status conference on the scheduling of responsive pleadings. Following the status conference on October 15, 2024, Paul Hastings prepared and filed the amended complaint [Docket No. 106 in Adv. Proc. No. 24-05249] on October 29, 2024 pursuant to the Court's scheduling order [Docket No. 102 in Adv. Proc. No. 24-05249]. On December 6, 2024 (i.e., after the Fee Period), Paul Hastings attorneys filed the Trustee's objection to defendants' motions to dismiss amended complaint [Docket No. 121 in Adv. Proc. No. 24-05249].

111. Pursuant to the Court's scheduling and severance order [Docket No. 102 in Adv. Proc. No. 24-05249], the First Omnibus Alter Ego Adversary Proceeding is severed into two separate adversary proceedings, whereby the Trustee's claims against the Moving Defendants are to proceed under a new docket number assigned to the same judge [Adv. Proc. No. 24-05318] (the "Severed OAE Adversary Proceeding"). During the Fee Period, Paul Hastings attorneys also (a) handled settlement discussion with defendant Karin Maistrello who, as alleged in the Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 53 of 879

complaint, is the nominal sole owner of the defendant Alfa Global Ventures Limited, (b) prepared the Trustee's Motion for Entry of Consented to Stipulated Judgment with respect to defendant Karin Maistrello [Docket No. 104 in Adv. Proc. No. 24-05318], and (c) handled the hearing on such motion on November 19, 2024. On November 26, 2024, the Court entered the stipulated judgment with respect to defendant Maistrello [Docket No. 109 in Adv. Proc. No. 24- 05318].

112. Moreover, during the Fee Period, Paul Hastings attorneys continued to analyze legal issues relating to international service and coordinate service of the complaint and summons on the defendants. In connection information and/or exhibits cited in the complaint and subsequently the amended complaint that have been designated "Confidential" or "Highly Confidential" pursuant to the Protective Order [Docket Nos. 923, 3264], Paul Hastings attorneys also analyzed the confidentiality designation of such exhibits and redaction applied to the complaint and subsequently the amended complaint.

113. Furthermore, during the Fee Period, Paul Hastings attorneys continued to prepare the new omnibus alter ego complaint, analyze factual and legal issues in connection with such new complaint, and hold internal conferences to further discuss and strategize. On December 23, 2024 (i.e., after the Fee Period), Paul Hastings attorneys prepared and filed another adversary complaint [Docket No. 1 in Adv. Proc. No. 24-05322] (the "Second Omnibus Alter Ego Adversary Proceeding") against more than forty entities—each nominally owned by a family member or associate of the Individual Debtor)—seeking rulings that such entities are alter egos of the Individual Debtor and/or their assets are beneficially owned by the Individual Debtor, such that their assets are property of the estate. XVII. Avoidance Actions (Matter ID 00029)

- i. Court Hearings (Task Code B155) Fees: \$44,026.50 Total Hours: 23.40 - 114. During the Fee Period, Paul Hastings attorneys prepared for and attended

numerous hearings and status conferences regarding the Avoidance Actions. The following

hearings were recorded under Matter ID 00029, among others:

- the August 13, 2024 hearing on the Trustee's first supplemental motion to extend deadline to file avoidance actions; - the September 6, 2024 status conference on appeals of the Bankruptcy Court's order extending the Trustee's deadline to file avoidance action; - the September 24, 2024 status conference on the mediation and avoidance action procedures order, the mediation stay, and issues relating to the defendants' motions to dismiss; - the November 19, 2024 hearing on the Trustee's motion for default judgment as to the Avoidance Action against Cirrus Design Corporation and Qiang Guo. - ii. General Litigation (Task Code B191) Fees: \$1,190,681.50 Total Hours: 792.30

115. During the Fee Period, Paul Hastings attorneys, in coordination with Kroll and NPM, continued to analyze potential avoidance actions claims (for instance, with respect to professional services firms) and conducted related research. Paul Hastings attorneys also assisted NPM with preparing additional Avoidance Action complaints. Ultimately, the Trustee has now filed a total of more than 300 Avoidance Actions seeking the avoidance of fraudulent and post-petition transfers made by the Individual Debtor through his shell companies. In order to minimize costs, the large majority of these complaints were prepared and filed by NPM.

116. Paul Hastings attorneys, in coordination with NPM, also (a) prepared and filed the Trustee's responses to various Avoidance Action defendants' motions to dismiss, (b) prepared and filed the Trustee's response to motion to withdraw the references filed by various Avoidance Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 55 of 879

Action defendants, (c) prepared and filed the Trustee's motion for judgment on the pleadings with respect to the Trustee's adversary complaint as against Zeisler & Zeisler, P.C, (d) analyzed other litigation-related issues, including appeals of the Court's order granting the Trustee's motion to extend deadline to file avoidance actions and responding to third party complaint filed in the avoidance actions, and (e) continued to meet and confer with counsel for Avoidance Action defendants.

117. As discussed above, Paul Hastings attorneys, in coordination with NPM, prepared the Trustee's motion to extend the August 15, 2024 deadline for the Trustee to commence actions to avoid and recover fraudulent transfers and/or assert other estate causes of action (which motion was filed on July 19, 2024), and related motions to limit service. The Court granted this motion to extend deadline by order dated August 14, 2024.

118. Furthermore, on November 13, 2024 and November 20, 2024, respectively, the Bankruptcy Court granted the Trustee's motions for entry of default judgment in Avoidance Actions against Qiang Guo, the Debtor's son, with respect to more than \$20 million transfer from the Individual Debtor's alter ego, Lamp Capital, to Qiang Guo, and approximately \$4 million transfers from the Individual Debtor's alter egos, Lamp Capital, HCHK Technologies, and Leading Shine, for the benefit of Qiang Guo.

119. During the Fee Period, Paul Hastings attorneys also prepared for and attended the September 24, 2024 status conference, following which, the Court entered an order further amending the avoidance action procedures order and scheduling joint briefing of motions to dismiss and motions for judgment on the pleadings [Docket No. 3577]. In this regard, Paul Hastings attorneys (a) reviewed and analyzed the joint defendants' motion to dismiss, (b) Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 56 of 879

prepared and filed the Trustee's objections to the joint defendants' motion to dismiss, and (c) further analyzed the joint defendant's joint reply.

120. In addition, Paul Hastings attorneys continued to meet and confer with counsel for Avoidance Action defendants as well as discussed and analyzed potential settlements and prepared settlement agreements.

121. During the Fee Period, Paul Hastings attorneys also continued to analyze and coordinate the service of the Avoidance Action complaints on the respective defendants, including international service in accordance with the Hague Convention.

i. General Litigation (Task Code B191) Fees: \$112,642.00 Total Hours: 66.80

122. During the Fee Period, Paul Hastings attorney, in coordination with NPM, (a) continued to prepare for and conduct mediation sessions, (b) analyzed legal issues and case law concerning the mediation and settlement, (c) prepared for mediation sessions, (d) prepared for and held discussions with Judge Tancredi, as the mediator, about the mediation process, and (e) held internal meetings to discuss strategy and analyze case materials in connection with mediation and potential settlements.

i. General Litigation (Task Code B191) Fees: \$372,244.50 Total Hours: 210.70

123. In connection with the Individual Debtor's Criminal Case, the U.S. Government has seized and sought forfeiture of more than \$630 million in various accounts, as well as various other assets controlled by the Individual Debtor (the "Seized Assets") as identified in the third Superseding Indictment [Criminal Case Docket No. 307] and later in the Consent Preliminary Order of Forfeiture as to Specific Property/Money Judgment [Criminal Case Docket Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 57 of 879

No. 488]. The Seized Assets and/or the entities in whose name they were held are also subjects of various adversary proceedings commenced by the Trustee. Thus, navigating and resolving forfeiture issues with the U.S. Government is of critical importance to the interest of the estate and of the Individual Debtor's creditors, to whom the Trustee owes fiduciary duties.

124. In light of the above, during the Fee Period, Paul Hastings attorneys (a) reviewed and analyzed legal issues and case law regarding criminal forfeiture, (b) prepared presentation slides and related materials, (c) held internal conferences to discuss and strategize, and (d) held meeting and discussion with the U.S. Government to discuss related issues.

i. General Litigation (Task Code B191) Fees: \$88,554.00 Total Hours: 55.00

125. During the Fee Period, Paul Hastings attorneys, in coordination with NPM, continued to prosecute the Trustee's claims as against K Legacy Limited ("K Legacy") and Qiang Guo. On September 12, 2024, the Court, upon motion of the Trustee, entered default judgment against K Legacy and Qiang Guo, pursuant to which the Court held, among other things, that the ownership interests in K Legacy and the assets of K Legacy, including the Individual Debtor's luxury apartment in London, are property of the estate [Docket No. 76 in Adv. Proc. No. 24-05249].

126. In addition, Paul Hastings attorneys, in coordination with the Trustee's BVI counsel, Harneys and Mr. James Morgan, continued to prosecute proceedings commenced by the Trustee in the BVI, i.e., the jurisdiction where K Legacy is incorporated, to among other things, seek rulings that the Trustee beneficially owns K Legacy and the London apartment. ii. Investigations (Task Code B261) Fees: \$17,493.00 Total Hours: 9.80

127. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's claims as against K Legacy and Qiang Guo. A critical aspect of the Trustee's investigation and litigation is to analyze the ownership and corporate structure of K Legacy, an entity organized in the BVI which purportedly holds title to the Individual Debtor's luxury apartment in London.

128. In light of the above, during the Fee Period, Paul Hastings attorneys, in coordination with the Trustee's BVI counsel, Harneys, prepared a disclosure application in the BVI court with respect to K Legacy.

i. Investigations (Task Code B261) Fees: \$198,465.00 Total Hours: 134.30

129. As alleged by the U.S. Government in the Superseding Indictment, the Individual Debtor and his associates transferred and directed the transfer of hundreds of millions of dollars into and through more than approximately 500 accounts held in the names of at least 80 different entities or individually, including bank accounts in Switzerland. In addition, through his diligent investigation efforts, the Trustee has reason to believe that there are assets of the Individual Debtor's estate potentially located in Switzerland.

130. Following the recognition of the Individual Debtor's chapter 11 case in Switzerland by the Swiss court, during the Fee Period, Paul Hastings attorneys, in coordination with the Trustee's Swiss counsel, Prager, (a) continued to conduct investigation into Individual Debtor's assets in Switzerland, (b) reviewed and analyzed legal issues relating to asset investigation in Switzerland, and (c) held internal conferences and conference with Prager to discuss the investigation and litigation strategy. XXII. Cyprus Proceedings (Matter ID 00034)

i. General Litigation (Task Code B191) Fees: \$83,890.50 Total Hours: 59.90

131. As discussed above, in the course of his investigation into the Individual Debtor's financial affairs, the Trustee discovered assets (including real property) located, and transfers that took place, in Cyprus. As a result, during the Fee Period, Paul Hastings attorneys prepared complaint against among others, Bouillor Holdings Limited ("Bouillor"), a Cyprus entity nominally owned by Qiang Guo, son of the Individual Debtor, to recover the Individual Debtor's luxurious high-rise apartment in Limassol, Cyprus (the "Bouillor Adversary Proceeding"). In the Bouillor Adversary Proceeding, the Trustee seeks, among other things, a ruling from this Court that the Individual Debtor is the true beneficial owner of Bouillor and its assets which include the luxurious apartment in Cyprus, and a ruling ordering turnover of Bouillor and its assets to the Trustee

132. In addition, Paul Hastings attorneys, in cooperation with the Trustee's Connecticut counsel, NPM, and Cyprus counsel, CP Law, (a) reviewed and analyzed legal issues relating to the Bouillor Adversary Proceeding, (b) coordinated service of process in Cyprus, and (c) prepared filings in Cyprus court in connection with the relief requested in the Bouillor Adversary Proceeding. XXIII.Mauritius Proceedings (Matter ID 00035)

i. General Litigation (Task Code B191) Fees: \$49,367.50 Total Hours: 33.80

133. As discussed above, the Trustee has learned through his investigation that Himalaya International Clearing, one of the defendants in the First Omnibus Alter Ego Adversary Proceeding, made an application in Mauritius to request the release of funds nominally held under Himalaya International Clearing's name in Silver Bank Limited, which is Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 60 of 879

subject to proceedings currently pending in the Chambers Commercial Division of the Supreme Court of Mauritius (the "Mauritius Action"). As the Court is well aware, the Trustee seeks a ruling from this Court in the First Omnibus Alter Ego Adversary Proceeding that Himalaya International Clearing is the alter ego of and equitably owned by the Individual Debtor, and that therefore, the funds in the Himalaya International Clearing's account at Silver Bank are property of the estate.

134. In light of the above, during the Fee Period, Paul Hastings attorneys, in coordination with the Trustee's Mauritius counsel, (a) reviewed and analyzed legal issues relating to the Mauritius Action, (b) prepared recognition application of the Trustee in Mauritius, and (c) held internal conferences and conference with Mauritius counsel to discuss case and investigation strategies.

i. Investigations (Task Code B261) Fees: \$30,300.50 Total Hours: 20.80

135. As alleged by the U.S. Government in the Superseding Indictment, the Individual Debtor and his associates transferred and directed the transfer of hundreds of millions of dollars into and through more than approximately 500 accounts held in the names of at least 80 different entities or individually, including bank accounts in the UAE. In addition, through his diligent investigation efforts, the Trustee has reason to believe that there are assets of the Individual Debtor's estate potentially located in the UAE.

136. In light of the above, during the Fee Period, Paul Hastings attorneys, in cooperationg with the Trustee's UAE counsel, Kobre & Kim, (a) continued his investigation into Individual Debtor's assets in the UAE, (b) reviewed and analyzed legal issues relating to the Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 61 of 879

asset investigation in the UAE, and (c) held internal conferences and conference with Kobre & Kim to discuss case and investigation strategies. XXV. Hamilton UK Administration (Matter ID 00037) i. General Litigation (Task Code B191) Fees: \$113,689.00 Total Hours: 72.00

137. As discussed above, the Trustee has learned through his investigation that Hamilton Capital Holding, one of the defendants in the First Omnibus Alter Ego Adversary Proceeding, entered into purported administration in the United Kingdom (the "Hamilton UK Administration") in or about August 2024. Based on review of documents relating to the administration, the Trustee has reason to believe that the Hamilton UK Administration is an attempt to recycle funds and redistribute them to the Individual Debtor, William Je, and associated entities by using the administration proceeding to "cleanse" such funds. As the Court may recall, the Individual Debtor and his associates attempted a similar strategy to recycle and redistribute funds with the HCHK Entities that commenced a New York state law assignment proceeding in April 2023, which the Trustee successfully sought to enjoin.

138. In light of the above, during the Fee Period, Paul Hastings attorneys, in coordination with the Trustee's UK counsel, (a) reviewed and analyzed filings and documents relating to the Hamilton UK Administration, (b) analyzed legal issues concerning the Hamilton UK Administration, (c) prepared filings in the UK court, and (d) held internal conferences and conference with UK counsel to discuss case and investigation strategies.

139. 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 Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 62 of 879

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).24

140. 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).

141. 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., 25 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

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

25 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. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 63 of 879

(2d Cir. 2007) (citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir.1974), abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87, 92–93, 96 (1989)). The "lodestar method" of calculating the reasonable fee contemplates "the number of hours reasonably expended . . . multiplied by a reasonable hourly rate." See Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); Gisbrecht v. Barnhart, 535 U.S. 789, 801 (2002); Perdue v. Kenny A., 130 S.Ct. 1662, 1672 (2010); In re Drexel Burnham Lambert Grp., Inc., 133 B.R. 13 (Bankr. S.D.N.Y. 1991). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544 F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.26 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").

142. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Paul Hastings is fair and reasonable, as set forth below and otherwise in this Application.

Paul Hastings billed a total of \$5,542,465.25 and 3,998.40 hours of professional and paraprofessional services during the Fee Period. As evidenced by this Application, Paul Hastings professionals and paraprofessionals worked diligently and efficiently without unnecessary duplication of efforts throughout the Fee Period. A small group of the same Paul Hastings attorneys was utilized for the vast majority of the work in order to minimize the costs of intra-Paul Hastings communication and education about the Debtors' circumstances. Whenever

26 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).

possible, Paul Hastings sought to minimize the cost of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. The services were performed in an effective and efficient manner commensurate with the complexity, exigency, and importance of the issues involved. In addition, Paul Hastings' representation has required it to balance the need to provide quality services with the need to act quickly and represent the Trustee and the Genever Debtors in an effective, efficient, and timely manner. Paul Hastings submits that the hours spent were reasonable given the size and complexity of these chapter 11 cases, the significant, and often urgent, legal and business issues raised, and the numerous pleadings filed in the chapter 11 cases. Furthermore, as noted detailed above, the Trustee and the Genever Debtors also retained NPM as local and conflicts counsel in order to provide services to the Trustee and the Genever Debtors in a costeffective manner. Paul Hastings and NPM have coordinated and will continue to coordinate each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. b. Novelty and Difficulty of the Questions

Paul Hastings tasked knowledgeable attorneys to research, analyze, and advise the Trustee and the Genever Debtors on difficult and complex issues during the Fee Period, including issues related to bankruptcy and litigation. Most notably, as detailed in this Application, Paul Hastings investigated complex estate claims and causes of action in order to recover assets of these estates. c. Skill Requisite to Perform the Legal Services Properly

Paul Hastings believes that its recognized expertise in the areas of financial restructuring and corporate reorganization, its ability to draw from highly experienced professionals in other areas of Paul Hastings' practice, and its creative approach to the resolution of issues has contributed to the effective administration of these chapter 11 cases and benefited the Trustee, the Genever Debtors, their estates, and their unsecured creditors. Due to the nature and complexity of the legal issues presented by these chapter 11 cases, Paul Hastings was required to exhibit a high degree of legal skill in areas related to, among others, bankruptcy and litigation. d. Preclusion of Other Employment by Applicant Due to Acceptance of the Case

Due to the size of Paul Hastings' restructuring and litigation departments, Paul Hastings' representation of the Trustee and the Genever Debtors did not preclude its acceptance of new clients, but the demands for immediate and substantive action in these chapter 11 cases imposed significant burdens on Paul Hastings professionals and paraprofessionals working concurrently on other matters. That said, for the Trustee, his engagement as a chapter 11 trustee has, for all practical purposes precluded other employment given that this matter is taking up most of his time.

Other than the hourly rate for Luc A. Despins (which has been reduced from his standard hourly rate of \$2,225.00 to \$1,975.00), the fees charged by Paul Hastings in these chapter 11 cases are billed in accordance with its existing billing rates and procedures in effect during the Fee Period. The rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. Moreover, when Paul Hastings' restructuring professionals and paraprofessionals work on nonbankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable nonbankruptcy cases in a competitive national legal market. In addition, the firm's customary hourly rates and rate structure reflect that restructuring and related matters typically involve great complexity, numerous tasks requiring a high level of expertise, and severe time pressures, as is the case here. f. Whether the Fee Is Fixed or Contingent

Pursuant to Bankruptcy Code sections 330 and 331, all fees sought by professionals employed under Bankruptcy Code section 1103 are subject to final approval by the Court, and are subject to adjustment depending on the services rendered and the results obtained. Of particular note, payment of Paul Hastings' fees here was contingent in two respects: (1) the recovery of assets for the benefit of the estates and (2) monetizing such assets. At the outset of these chapter 11 cases, there was no assurance whatsoever that assets would be recovered and monetized to allow for the payment of estate professionals. Accordingly, Paul Hastings' compensation was, in essence, a contingency fee arrangement. The risk that Paul Hastings assumed by representing the Trustee and the Genever Debtors further supports the reasonableness of Paul Hastings' compensation. g. Time Limitations Imposed by the Client or Other Circumstances

During the Fee Period, Paul Hastings was required to analyze and address certain issues arising in these chapter 11 cases under compressed timelines. For example, given the Individual Debtor's track record of moving assets to keep them out of reach of creditors, it was critical that Paul Hastings act quickly on information obtained during the Trustee's investigation in order to freeze assets.

Paul Hastings professionals and paraprofessionals worked diligently to maximize value for these chapter 11 estates. During the Fee Period, and as described in the summary of services herein, Paul Hastings was instrumental in analyzing potential sources of recovery for the benefit of these estates. During the Fee Period, Paul Hastings was able to secure several key rulings from the Court, which rulings will serve as a beachhead for future asset recovery efforts. The reasonableness of Paul Hastings' fees must be evaluated in light of this important strategic factor. i. Experience, Reputation, and Ability of Attorneys

Paul Hastings is consistently recognized as a top tier law firm in the field of business reorganizations and liquidations under chapter 11 of the Bankruptcy Code. During the Fee Period, Paul Hastings solicited the skill and expertise of its professionals and paraprofessionals. Paul Hastings professionals have actively represented debtors, creditors, and creditors' committees, as well as other parties in interest, in a number of the nation's largest chapter 11 cases as well as in connection with cross-border restructurings. Paul Hastings' extensive experience enables it to perform the services described herein competently and expeditiously. In addition to its expertise in the area of corporate reorganization, Paul Hastings has called upon the expertise of its attorneys in other practice areas as required during the Fee Period.

As detailed in this Application, the Individual Debtor's in-court and out-of-court tactics illustrate the undesirability of this engagement, which involved harassment of the Trustee and Paul Hastings attorneys (including death threats against the Trustee). As a result, Paul Hastings was forced to incur hundreds of thousands of dollars in cyber security measures (the cost of which are not part of the expenses for which Paul Hastings is seeking reimbursement in this Application). In addition, prior to the Court granting the First Interim Fee Application at the end of June 2023, Paul Hastings was unable to be paid for its fees for nearly a year. k. Nature and Length of Professional Relationship

Paul Hastings has been rendering professional services to (a) the Trustee since its retention as counsel effective as of July 8, 2022, (b) Genever (BVI) since its retention as counsel effective as of October 11, 2022, and (c) Genever (US) since its retention as counsel effective as of November 3, 2022.

143. Paul Hastings respectfully submits that the services for which it seeks

compensation in this Fee Application were, at the time rendered, necessary for and beneficial to the Debtors' estates and their creditors and were rendered to maximize, protect, and preserve value for the Debtors' estates and all parties in interest. Paul Hastings believes that it provided services economically, effectively, and efficiently, and obtained results beneficial to the Debtor's estate and his creditors. Paul Hastings further submit that the compensation requested herein is reasonable in light of the nature, extent, and value of the services rendered during the Fee Period.

144. Paul Hastings also notes that the rates charged during the Fee Period are reasonable. In fact, this Court held that Paul Hastings' New York rates are reasonable because Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 67 of 879

Paul Hastings was retained at New York rates and these cases are extraordinary within this District. See Order Denying Motion for Stay Pending Appeal [Docket No. 1791].

145. All fees incurred by Paul Hastings during the Fee Period were actual, reasonable, and necessary in the performance of services for the Trustee and the Genever Debtors. Paul Hastings respectfully requests approval of the compensation sought herein.

146. As set forth in Exhibit C hereto, Paul Hastings incurred and disbursed \$215,048.30 as expenses in providing professional services during the Fee Period. These expenses include approximately \$23,857.44 for online legal research (i.e., LEXIS and Westlaw). Because Paul Hastings believes that online legal research (e.g., LEXIS and Westlaw) is far more cost-efficient than manual research using hard-bound volumes, Paul Hastings encourages computerized legal research even though it is not a profit center for Paul Hastings. To be clear, Paul Hastings does not charge a mark-up on the LEXIS and Westlaw charges, but merely passes on the costs of such third-party services. Moreover, as it relates to outside professional services, mailing, and other service-related expenses, the Trustee and Paul Hastings are merely passing on the costs of such third-party services, without any mark-up.27

- 147. Additional necessary expenses included: - \$149,315.59 for certain outside professional services, such as document review services by UnitedLex; - \$14,047.50 for process servers (e.g., Ancillary Legal Corporation) to serve, among other things, the subpoenas issued pursuant to the Rule 2004 orders entered by this Court; - \$6,788.44 for UPS/courier service, including service of pleadings required to be served in hard copy format; and

27 Documentation of these expenses will be made available to the Court upon request.

- \$2,655.30 for court reporting services; - \$2,312.56 for document reproductions, namely \$1,586.56 for b/w reproductions (at 8 cents per page) and \$726.00 for color reproductions (at 20 cents per page); - \$702.73 for corporate document retrieval services (including United Corporate Service and Corp2000) with respect to various Kwok-related entities.

148. During the Fee Period, Paul Hastings utilized UnitedLex -- a third party vendor that specializes in discovery services including document processing, storage, review services, and distribution -- to conduct document review of the documents produced in the chapter 11 cases, including the hundreds of thousands of discovery documents received by the Trustee to date in connection with his investigation.

149. Using their own contract attorneys and review team managers, UnitedLex provides an efficient and economic means of reviewing large document sets at hourly rates significantly lower than Paul Hastings. UnitedLex's document review team charges hourly rates ranging from \$40 to \$55 (for non-management roles) and \$150 (for management role), which is substantially less than Paul Hastings' hourly rates and, moreover, is even less than the hourly rates of associates of local Connecticut counsel (i.e., NPM), whose hourly rates range from \$220 to \$425. For all these reasons, Paul Hastings believes that utilizing the UnitedLex document review team greatly benefits these estates by reducing document review costs. The Trustee also previewed Paul Hastings' use of UnitedLex with the U.S. Trustee, who had no objection thereto (without the Trustee having to file a separate retention application for UnitedLex). The Trustee and Paul Hastings also disclosed in the Fourth Supplemental Declaration of Disinterestedness of Luc A. Despins [Docket No. 1435] that Paul Hastings would utilize UnitedLex's contract attorney services. Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 69 of 879

150. The time constraints imposed by the circumstances of the matters handled by Paul Hastings during the Fee Period required its attorneys and other employees, at times, to devote substantial time during the evenings and on weekends to perform legal services on behalf of the Trustee. These extraordinary services were essential to meet deadlines, timely respond to inquiries on a daily basis, and satisfy the Trustee's needs and demands. Attorneys and other Paul Hastings employees who worked late in the evenings or on weekends were reimbursed for their reasonable meal and transportation costs in accordance with firm policy. Paul Hastings' regular practice is not to include components for those charges in overhead when establishing billing rates, but rather to charge its clients for these and all other out-of-pocket disbursements incurred during the regular course of the provision of legal services.

151. In accordance with Appendix D (Guidelines for Compensation and Expense Reimbursement of Professionals) to the Local Rules, reproduction charges have been capped at 20 cents per page.28

152. The expenses requested herein are customarily charged to non-bankruptcy clients of Paul Hastings. Additionally, the expenses incurred by Paul Hastings to third parties are limited to the actual amounts billed to, or paid by, Paul Hastings on behalf of the estates.

153. Paul Hastings believes the rates for charges incurred are the market rates that the majority of law firms charge clients for such services. In addition, Paul Hastings believes that such charges are in accordance with the American Bar Association's ("ABA") guidelines, as set forth in the ABA's Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other charges.

28 Generally, Paul Hastings charges 8 cents per page for black-and-white reproductions and 50 cents per page for color reproductions. In accordance with Appendix D to the Local Rules, Paul Hastings has reduced the charge for color reproductions to 20 cents per page.

154. The expenses incurred in providing professional services in the Chapter 11 Case

were necessary, economical, and justified under the circumstances.

155. Paul Hastings responds to the questions set forth in Paragraph C.5. of the

U.S. Trustee Guidelines as follows:

Question: Did you agree to any variations from, or alternatives to, your standard or customary billing rates, fees, or terms for services pertaining to this engagement that were provided during the Fee Period?

Response: Yes. As a courtesy to these estates and based on circumstances unique to these chapter 11 cases, during the Fee Period, Paul Hastings agreed to voluntary fee reductions aggregating \$99,319.00, including the following:

Paul Hastings is not seeking allowance or payment at this time of the fees incurred twelve (12) timekeepers who billed less than five (5) hours during the Fee Period. The total amount of such fees is \$10,119.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

As a result of the agreed-upon reduction in Luc A. Despins' hourly rate (from his standard hourly rate of \$2,225 to the reduced hourly rate of \$1,975), an additional \$89,100.00 in fees have been waived. Question: If the fees sought in this application as compared to the fees budgeted for the Fee Period are higher by 10% or more, did you discuss the reasons for the variation with the client. Response: Not applicable. Question: Have any of the professionals included in this application varied their hourly rate based on the geographic location of the bankruptcy case?

Question: Does the application include time or fees related to reviewing or revising time records or preparing, reviewing, or revising invoices? (This is limited to work involved in preparing and editing billing records that would not be compensable outside of bankruptcy and does not include reasonable fees for preparing a fee application.) If so, please quantify by hours and fees.

Response: The Application does not include time for preparing, reviewing, or revising time records. However, the Application does include approximately 12.6 hours and associated fees of approximately \$19,989.50 related to preparing, reviewing, and revising Paul Hastings' fee statements and ensuring time entries are properly categorized by matter number and task code. On average, approximately 2.1 hours were spent on each of the six monthly fee statements prepared during the Fee Period. Question: Does this application include time or fees for reviewing time records to redact any privileged or other confidential information? If so, please quantify by hours and fees. Response: No. Question: If the application includes any rate increases since retention: (i) Did your client review and approve those rate increases in advance? (ii) Did your client agree when retaining the law firm to accept all future rates increases? If not, did you inform your client that they need not agree to modified rates or terms in order to have you continue the representation consistent with ABA Formal Ethics Opinion 11-458? Response: As is customary, Paul Hastings adjusts its hourly rates periodically based upon (i) the advancing seniority of its professionals and paraprofessionals, (ii) the current market for legal services, (iii) the rates charged for comparable non‐ bankruptcy services, and (iv) the firm's analysis of the hourly rates being charged by professionals in other law firms. Effective January 1, 2023, September 1, 2023, and January 1, 2024, Paul Hastings adjusted its hourly rates consistent with the Retention Order [Docket Nos. 668 and 1376] and the

2450].

Notices of Change in Hourly Rates of Paul Hastings LLP, Counsel to Chapter 11 Trustee [Docket Nos. 1251, 2075, and

156. To the extent that time or disbursement charges for services rendered or expenses incurred during the Fee Period are not included in this Application, or the Trustee and Paul Hastings have for any reason not sought compensation or reimbursement with respect to such services (including, as noted above, services related to the preparation and prosecution of the Civil RICO Adversary Proceeding), Paul Hastings reserves the right to request compensation and reimbursement for such services in a supplemental or future application in the Debtors' chapter 11 cases. Also, Paul Hastings 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.

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

[Remainder of page intentionally left blank.] Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 73 of 879

WHEREFORE, Paul Hastings respectfully requests entry of an order, substantially in the form attached hereto as Exhibit G, (i) allowing interim compensation for professional services rendered during the Fee Period in the amount of \$5,542,465.25 and reimbursement of \$215,048.30 in expenses, (ii) authorizing payment from the Debtors' estates of (a) 80% of the aforementioned fees (minus a credit of \$87,292.80 with respect to agreed fee reductions under the Sixth Interim Fee Order), i.e., \$4,346,679.40, and (b) 100% of the expense reimbursements (minus a credit of \$2,000.00 with respect to agreed expense reductions under the Sixth Interim Fee Order), i.e., \$213,048.30, in the aggregate amount of \$4,559,727.70, (iii) allowing such compensation and payment for professional services rendered and reimbursement of actual and necessary expenses incurred without prejudice to the Trustee's and Paul Hastings' right to seek further compensation and/or payment from the Debtors' estates for the full value of services performed and expenses incurred, and (iv) granting the Trustee and Paul Hastings such other and further relief as is just.

Dated: February 24, 2025 New York, New York

> By: /s/ G. Alexander Bongartz G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com

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

Counsel for the Chapter 11 Trustee, Genever

Holdings Corporation, and Genever Holdings LLC UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

In re: :

HO WAN KWOK, et al., :

Debtors. :

The undersigned hereby certifies that on the date hereof, the foregoing Application was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case by operation of the Court's electronic filing ("CM/ECF") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing.1 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.

Dated: February 24, 2025 New York, New York

> By: /s/ G. Alexander Bongartz G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com

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

1 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.

Customary and Comparable Compensation Disclosures

The blended hourly rate for Paul Hastings' timekeepers in its New York and Washington, D.C. offices who billed to non-bankruptcy matters (collectively, the "Non-Bankruptcy Matters")1 during the twelve-month period beginning on December 1, 2023 and ending on November 30, 2024 was, in the aggregate, approximately \$1,289 per hour. The blended hourly rate for Paul Hastings' timekeepers who billed to these chapter 11 cases during the Fee Period was approximately \$1,386 per hour. A detailed comparison of these rates follows:

Category of Timekeeper Blended Hourly Rate

Blended Hourly Rate Debtor Blended Hourly

All Timekeepers Aggregated \$1,289 \$1,386

1 It is the nature of Paul Hastings' practice that certain non-bankruptcy engagements require the advice and counsel of professionals and paraprofessionals who work primarily within Paul Hastings' restructuring group. Accordingly, Non-Bankruptcy Matters consist of matters for which Paul Hastings' timekeepers represented a client in matters other than court-approved engagements as counsel for the debtor, the chapter 11 trustee, or an official committee under the Bankruptcy Code. As such, the Non-Bankruptcy Matters include, in part, time billed by Paul Hastings' timekeepers who work primarily within Paul Hastings' restructuring group.

2 Luc A. Despins brings to the Title III Cases over 36 years of experience representing debtors and creditors in high profile and complex restructuring matters. Given the complexity and challenges faced by the Trustee in these cases, a significant amount of time by senior partners, of counsel, and senior associates, including Mr. Despins, Nicholas Bassett, Alexander Bongartz, Shlomo Maza, and Douglass Barron has been necessary. Because their rates are at the higher end of the range of rates billed by Paul Hastings partners, of counsel, and associates, respectively, and in light of the fact that a significant amount of senior partner, of counsel, and senior associate time has been required for this engagement, the blended rate for this case moved to the higher end of the range of rates billed by Paul Hastings. Finally, the blended attorney hourly rate for the Fee Period is not comparable to the average hourly rate in other matters because it does not reflect numerous cost-saving measures, including the delegation of a variety of matters to NPM, matters for which otherwise more junior Paul Hastings attorneys with lower hourly rates would have been used, thereby reducing Paul Hastings' blended hourly rate.

Summary of Timekeepers Included in this Application

Bassett, Nicholas Corporate, 2007 \$1,835.00 438.00 \$803,730.00 3 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$917.50 20.20 \$18,533.50 3 Despins, Luc Restructuring, 1986 \$1,975.00 354.20 \$699,545.00 1 Despins, Luc (travel; ½ rate) Restructuring, 1986 \$987.50 4.40 \$4,345.00 1 Tsao, Leo Litigation, 1999 \$1,775.00 32.30 \$57,332.50 2

Bongartz, Alex Restructuring, 2007 \$1,850.00 244.20 \$451,770.00 3 Bongartz, Alex (travel, ½ rate) Restructuring, 2007 \$925.00 1.20 \$1,110.00 3 Maza, Shlomo Corporate, 2012 \$1,850.00 382.00 \$706,700.00 3 Traxler, Katherine Restructuring, 1990 \$1,120.00 8.10 \$9,072.00 3

Barron, Douglass Corporate, 2012 \$1,395.00 659.40 \$919,863.00 3 Catalano, Kristin Corporate, 2021 \$1,185.00 139.20 \$164,952.00 3 Farmer, Will Corporate, 2018 \$1,390.00 52.30 \$72,697.00 3 Kim, Sarah Litigation, 2023 \$985.00 11.90 \$11,721.50 1 Kosciewicz, Jon Litigation, 2021 \$1,185.00 93.50 \$110,797.50 3 Rubinfeld, Mila Corporate, 2021 \$565.00 12.50 \$7,062.50 N/A Sadler, Tess Corporate, 2019 \$1,365.00 37.10 \$50,641.50 3 Simon, Tori Corporate, 2024 \$795.00 38.10 \$30,289.50 N/A Song, Luyi Corporate, 2023 \$985.00 678.80 \$668,618.00 3 Song, Luyi (travel; ½ rate) Corporate, 2023 \$492.50 3.10 \$1,526.75 3 Sutton, Ezra Corporate, 2021 \$1,270.00 439.50 \$558,165.00 3 Sutton, Ezra (travel, ½ rate) Corporate, 2021 \$635.00 0.90 \$571.50 3 Associate Total 2,166.30 \$2,596,905.75

Boyle, Terrence Paralegal \$565.00 6.80 \$3,842.00 N/A Doherty, Allison Paralegal \$445.00 24.30 \$10,813.50 N/A Laskowski, Mat Paralegal \$565.00 25.60 \$14,464.00 2 Mohamed, David Paralegal \$565.00 290.80 \$164,302.00 2 Paraprofessional Total 347.50 \$193,421.50

Summary of Timekeepers Not Included in this Application3

Name Department; Date of First Admission Hourly

Timofeyev, Igor Litigation, 2007 \$1,835.00 0.40 \$734.00

Chan, Alex Corporate, 2022 \$985.00 2.00 \$1,970.00 Houben, Sabine Corporate, 2015 \$1,395.00 0.80 \$1,116.00 Selva, Gianmarco Corporate, 2020 \$565.00 1.00 \$565.00

Cairns, Dennis Court Services Coordinator \$405.00 1.50 \$607.50 Chang, Irene Legal Research Analyst \$420.00 1.70 \$714.00 Ecklund, Amy Technical Operations Senior Analyst \$440.00 0.50 \$220.00 Fernandez, Piscilla Paralegal \$580.00 2.80 \$1,624.00 Liu, Kelly Legal Research Analyst \$420.00 2.90 \$1,218.00 Timoney, Caroline Legal Research Analyst \$420.00 1.50 \$630.00 Wong, Fanny Senior Company Secretarial Manager \$685.00 0.50 \$342.50 Wortman, Lauren Legal Research Analyst \$420.00 0.90 \$378.00 Paraprofessional Total 12.30 \$5,734.00

3 As noted, as an accommodation to these estates, Paul Hastings is not seeking allowance or payment at this time for the fees of timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$10,690.50. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

Summary of Compensation by Project Category

U.S. Trustee Task Code and Project Category Hours

B110 Case Administration 179.20 \$196,816.50 B113 Pleadings Review 176.80 \$100,315.00 B130 Asset Disposition 7.70 \$8,747.00 B131 Sale of Real Estate 59.60 \$115,145.50 B155 Court Hearings 171.60 \$255,774.50 B160 Employment / Fee Applications (Paul Hastings) 56.80 \$75,461.50 B165 Employment / Fee Applications (Other Professionals) 128.20 \$189,389.00 B191 General Litigation 2,451.30 \$3,556,848.00 B195 Non-Working Travel 29.80 \$26,086.75 B210 Business Operations 55.60 \$76,049.50 B211 Financial Reports (Monthly Operating Reports) 16.20 \$21,590.00 B231 Security Document Analysis 6.20 \$10,345.50

B261 Investigations 662.80 \$897,353.00 B310 Claims Administration and Objections 1.10 \$1,334.00 B320 Plan and Disclosure Statement (including Business Plan) 0.70 \$829.50

Voluntary fee reduction related to timekeepers who billed less than five (5)

Summary of Compensation by Matter ID (Fee Period)

ID Matter Name August 2024 September 2024 October 2024 November 2024 Total Fees

Representation \$122,269.00 \$203,056.50 \$211,647.25 \$132,857.00 \$669,829.75

Litigation \$220,884.00 \$221,738.00 \$194,566.75 \$155,267.75 \$792,456.50 00003 Other Litigation \$3,279.50 \$11,810.00 \$689.50 \$26,835.50 \$42,614.50 00005 Sale Process \$9,720.00 \$13,812.50 \$75,967.00 \$16,583.75 \$116,083.25 00006 Tax Issues \$4,589.00 \$6,475.00 \$9,435.00 \$0.00 \$20,499.00 00007 Foreign Law Issues \$420.00 \$873.50 \$0.00 \$0.00 \$1,293.50 00010 Genever US \$15,110.50 \$6,484.50 \$12,841.00 \$4,638.00 \$39,074.00 00011 Genever BVI \$7,385.50 \$2,405.00 \$1,504.00 \$0.00 \$11,294.50 00012 Mahwah Adversary \$208,702.50 \$166,140.50 \$85,709.50 \$196,974.00 \$657,526.50 00014 HCHK Adversary \$2,698.50 \$3,979.00 \$4,325.00 \$0.00 \$11,002.50 00015 Interpleader Adversary \$0.00 \$1,101.00 \$0.00 \$0.00 \$1,101.00 00016 Mei Guo Adversary \$0.00 \$8,044.50 \$4,771.00 \$26,307.50 \$39,123.00 00017 HK USA Adversary \$13,362.50 \$0.00 \$0.00 \$1,835.00 \$15,197.50 00020 Greenwich Land Adversary \$42,177.00 \$14,220.00 \$26,067.25 \$98.50 \$82,562.75 00024 Lamp Capital Adversary \$12,610.50 \$45,656.50 \$13,417.50 \$41,395.00 \$113,079.50 00026 Ace Decade Adversary \$24,399.50 \$6,737.50 \$8,856.50 \$24,155.00 \$64,148.50 00027 Defeng Cao Adversary \$370.00 \$12,789.50 \$24,710.50 \$2,783.00 \$40,653.00 00028 Omnibus Alter Ego Adversary \$127,997.00 \$17,138.50 \$246,873.00 \$139,043.50 \$531,052.00 00029 Avoidance Actions \$270,508.50 \$298,348.50 \$358,324.00 \$308,399.00 \$1,235,580.00 00030 Mediation \$53,358.00 \$21,730.50 \$11,786.50 \$25,767.00 \$112,642.00 00031 Forfeiture Issues \$105,347.00 \$192,423.00 \$36,643.00 \$37,831.50 \$372,244.50 00032 K. Legacy \$4,660.00 \$56,078.50 \$24,583.00 \$20,725.50 \$106,047.00 00033 Swiss Proceedings \$567.00 \$47,166.00 \$81,969.50 \$68,762.50 \$198,465.00 00034 Cyprus Proceedings \$23,363.00 \$49,753.50 \$8,403.50 \$3,389.50 \$84,909.50 00035 Mauritius Proceedings \$2,511.00 \$13,936.00 \$31,800.50 \$1,490.00 \$49,737.50 00036 UAE \$0.00 \$0.00 \$14,439.00 \$15,861.50 \$30,300.50 00037 Hamilton UK Administration \$58,349.00 \$6,264.50 \$49,453.50 \$0.00 \$114,067.00 TOTAL \$1,334,638.50 \$1,428,162.50 \$1,538,783.25 \$1,251.000.00 \$5,552,584.25 hours Voluntary fee reduction related to timekeepers who billed less than five (5) (\$4,888.00) (\$785.00) (\$252.00) (\$4,194.00) (\$10,119.00) NET TOTAL \$1,329,750.50 \$1,427,377.50 \$1,538,531.25 \$1,246,806.00 \$5,542,465.25

Summary of Compensation Requested1 by Matter ID (Case)

00001 General Chapter 11 Trustee Representation \$4,640,045.75 \$669,829.75 \$5,309,875.50 00002 Asset Recovery Investigation and Lit. \$14,718,680.52 \$792,456.50 \$15,594,435.25 00003 Other Litigation \$2,116,660.00 \$42,614.50 \$2,159,274.52 00004 Corporate Law Issues \$1,232,995.75 \$0.00 \$1,232,995.75 00005 Sale Process \$522,619.00 \$116,083.25 \$641,486.25 00006 Tax Issues \$43,845.50 \$20,499.00 \$61,560.50 00007 Foreign Law Issues \$412,673.50 \$1,293.50 \$413,967.00 00008 Plan Process Issues \$118,476.00 \$0.00 \$513,271.50 00010 Genever US \$1,365,501.25 \$39,074.00 \$927,577.75 00011 Genever BVI \$41,206.50 \$11,294.50 \$17,901.00 00012 Mahwah Adversary \$1,837,162.75 \$657,526.50 \$2,494,689.25 00013 Golden Spring Adversary \$275,121.50 \$0.00 \$275,121.50 00014 HCHK Adversary \$3,481,970.75 \$11,002.50 \$3,492,973.25 00015 Interpleader Adversary \$51,883.50 \$1,101.00 \$52,984.50 00016 Mei Guo Adversary \$567,432.50 \$39,123.00 \$606,555.50 00017 HK USA Adversary \$2,299,065.25 \$15,197.50 \$2,314,262.75 00018 Bravo Luck Adversary \$688,551.50 \$0.00 \$688,551.50 00019 SN Apartment Adversary \$35,214.00 \$0.00 \$35,214.00 00020 Greenwich Land Adversary \$2,553,608.25 \$82,562.75 \$2,636,171.00 00021 AIG Adversary \$70,122.00 \$0.00 \$70,122.00 00022 PAX Adversary \$5,037.50 \$0.00 \$5,037.50 00024 Lamp Capital Adversary \$378,917.50 \$113,079.50 \$491,997.00 00025 Civil RICO \$183,388.50 \$0.00 \$183,388.50 00026 Ace Decade Adversary \$406,464.50 \$64,148.50 \$470,613.00 00027 Defeng Cao Adversary \$149,650.50 \$40,653.00 \$190,303.50 00028 Omnibus Alter Ego Adversary \$422,221.06 \$531,052.00 \$953,273.06 00029 Avoidance Actions \$1,444,322.66 \$1,235,580.00 \$2,679,902.66 00030 Mediation \$296,586.54 \$112,642.00 \$409,228.54 00031 Forfeiture Issues \$60,149.00 \$372,244.50 \$432,393.50 00032 K. Legacy \$19,661.50 \$106,047.00 \$125,708.50 00033 Swiss Proceedings \$6,105.00 \$198,465.00 \$204,570.00 00034 Cyprus Proceedings \$0.00 \$84,909.50 \$84,909.50 00035 Mauritius Proceedings \$0.00 \$49,737.50 \$49,737.50 00036 UAE \$0.00 \$30,300.50 \$30,300.50 00037 Hamilton UK Administration \$0.00 \$114,067.00 \$114,067.00 TOTAL \$40,445,340.03 \$5,552,584.25 \$45,997,924.28 Voluntary fee reduction (\$248,584.97) (\$10,119.00) (\$258,703.97) NET TOTAL \$40,196,755.06 \$5,542,465.25 \$45,739,220.31

1 The fees listed in this chart are the fees requested by Paul Hastings in its various fee applications, and not the fees ultimately allowed by the Court. The fees ultimately allowed reflect additional agreed-upon reductions with the United States Trustee.

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 82 of 879

Airfare \$0.00 \$1,218.89 \$2,209.86 \$0.00 \$3,428.75 Articles and Publications \$0.00 \$0.00 \$0.00 \$6.61 \$6.61

Documents):

Corporation \$10,568.00 \$3,479.50 \$0.00 \$0.00 \$14,047.50 Computer Search (Other) \$500.49 \$570.06 \$678.78 \$86.40 \$1,835.73

Solutions \$0.00 \$0.00 \$708.00 \$0.00 \$708.00 Court Reporting Services \$0.00 \$2,655.30 \$0.00 \$0.00 \$2,655.30 Lexis/On Line Search \$440.76 \$114.91 \$78.58 \$607.00 \$1,241.25 Local - Meals \$268.13 \$735.55 \$418.11 \$145.58 \$1,567.37 Local - Parking \$0.00 \$0.00 \$6.00 \$8.00 \$14.00 Local - Taxi \$68.05 \$0.00 \$88.31 \$0.00 \$156.36 Lodging \$0.00 \$675.64 \$753.96 \$0.00 \$1,429.60 Messenger \$0.00 \$354.50 \$0.00 \$0.00 \$354.50 Outside Professional Services:

UnitedLex \$95,293.19 \$24,886.17 \$29,136.23 \$0.00 \$149,315.59 Postage/Express Mail \$563.97 \$340.84 \$883.10 \$843.89 \$2,631.80 Reproduction Charges \$156.48 \$308.96 \$776.48 \$344.64 \$1,586.56 Reproduction Charges (Color) \$538.00 \$188.00 \$0.00 \$0.00 \$726.00

Documents:

TransUnion Risk \$0.00 \$25.00 \$0.00 \$0.00 \$25.00

Other \$252.41 \$396.11 \$29.21 \$0.00 \$702.73 Search Fees \$226.53 \$2.05 \$0.00 \$228.58 Taxi/Ground Transportation \$0.00 \$639.03 \$855.67 \$248.02 \$1,742.72 Travel Expense - Meals \$0.00 \$8.15 \$163.76 \$0.00 \$171.91 UPS/Courier Service \$5,775.82 \$325.05 \$272.11 \$415.46 \$6,788.44 Vendor Expense \$41.97 \$176.30 \$22.44 \$852.10 \$1,092.81 Westlaw \$3,186.36 \$7,377.58 \$5,805.97 \$6,246.28 \$22,616.19 TOTAL \$117,880.16 \$44,475.54 \$42,888.62 \$9,803.98 \$215,048.30

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 83 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 February 7, 2025 Please Refer to Invoice Number: 2429376

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$122,269.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 February 7, 2025 Please Refer to Invoice Number: 2429376

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$122,269.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 86 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 February 7, 2025 Please Refer to Invoice Number: 2429376

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending August 31, 2024 General Chapter 11 Trustee Representation \$122,269.00

Date Initials Description Hours Rate Amount

08/01/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/01/2024 NAB Correspond with L. Despins regarding case

08/02/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/02/2024 NAB Call with P. Linsey (NPM) regarding general case strategy and updates 0.20 1,835.00 367.00 08/05/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/05/2024 LAD4 Weekly call with NPM with N. Bassett, L.

Date Initials Description Hours Rate Amount

08/05/2024 LS26 Investigation and litigation update call with P. Linsey (NPM), D. Skalka (NPM), L. Despins, N. Bassett 0.60 985.00 591.00 08/05/2024 NAB Call with L. Despins, L. Song, P. Linsey

general case updates and strategy 0.60 1,835.00 1,101.00 08/06/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/07/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/08/2024 AB21 Update list of open issues and workstreams 0.20 1,850.00 370.00 08/08/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group re same (.2); review and prepare new case documents for attorney review (.4) 1.30 565.00 734.50 08/09/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/12/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/12/2024 DEB4 Participate in case and litigation update call with P. Linsey (NPM), L. Despins, N. Bassett and L. Song (0.8); prepare follow up notes regarding same (0.1) 0.90 1,395.00 1,255.50 08/12/2024 LAD4 Handle part of weekly NPM call with N. Bassett, D. Barron, L. Song 0.40 1,975.00 790.00 08/12/2024 LS26 Call with L. Despins, N. Bassett, D. Barron,

regarding pending and upcoming litigation 0.80 985.00 788.00

Date Initials Description Hours Rate Amount

08/12/2024 NAB Call with L. Despins, D. Barron, P. Linsey

08/13/2024 AB21 Update list of open issues and workstreams 0.20 1,850.00 370.00 08/13/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/14/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/15/2024 DM26 Review certain case documents and prepare same for attorney review 0.30 565.00 169.50 08/15/2024 ECS1 Correspond with D. Mohamed re case

08/15/2024 LAD4 T/c C. Callari (Rui Ma's counsel) re: update (.30); t/c S. Millman (Hogan Lovells) re:

08/16/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/19/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/19/2024 DEB4 Participate in NPM call with P. Linsey, L. Despins, N. Bassett, and L. Song regarding pending and upcoming litigation 1.00 1,395.00 1,395.00 08/19/2024 LAD4 Weekly call with NPM and N. Bassett, D. Barron, L. Song 1.00 1,975.00 1,975.00 08/19/2024 LS26 Call with P. Linsey (NPM), D. Skalka (NPM), D. Barron, L. Despins, and N. Bassett regarding case matters and litigation 1.00 985.00 985.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 89 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376

Date Initials Description Hours Rate Amount

08/19/2024 NAB Attend call with P. Linsey (NPM), D. Skalka (NPM), L. Despins, D. Barron, and L. Song regarding general case updates and strategy 1.00 1,835.00 1,835.00 08/20/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/20/2024 ECS1 Correspond with D. Mohamed re pending and upcoming case matters and deadlines 0.10 1,270.00 127.00 08/21/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/21/2024 ECS1 Correspond with W. Farmer and P. Linsey

08/22/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

08/22/2024 DEB4 Correspond with L. Despins regarding

08/22/2024 ML30 Correspond with D. Mohamed re case issues and upcoming filings 0.50 565.00 282.50 08/22/2024 NAB Review presentation for update meeting

08/23/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 90 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376

Date Initials Description Hours Rate Amount

08/23/2024 ML30 Correspond with E. Sutton and D. Mohamed re pleadings to be filed by local counsel (.2); review same (.1); review and handle hard copy service of same (.2);

required parties (.2); correspond with E. Sutton re same (.1) 0.80 565.00 452.00 08/24/2024 DEB4 Correspond with L. Despins regarding strategy call with UCC and PAX 0.10 1,395.00 139.50 08/26/2024 DEB4 Correspond with L. Despins regarding

counsel regarding same (0.1); call with L.

and UCC regarding Trustee strategy (1.2) 1.50 1,395.00 2,092.50 08/26/2024 ECS1 Correspond with M. Laskowski and P.

upcoming deadlines 0.20 1,270.00 254.00 08/26/2024 LAD4 Review/edit power point presentation to

presentation on update to counsel for PAX

08/26/2024 NAB Participate in case update telephone

Committee and PAX professionals 1.20 1,835.00 2,202.00 08/29/2024 ML30 Revise notices of appearance for certain attorneys (.6); prepare e-filings of same (.3);

Subtotal: B110 Case Administration 30.70 33,660.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 91 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376

Date Initials Description Hours Rate Amount

08/01/2024 DM26 Review recent filings in Kwok case no. 22-

(.7); review related case dockets regarding recent filings (.5); research certain case documents per attorney request (.3) 1.90 565.00 1,073.50 08/02/2024 DM26 Review recent filings in Kwok case no. 22-

(.6); review related case dockets regarding recent filings (.5); research certain case documents per attorney request (.5) 2.00 565.00 1,130.00 08/05/2024 DM26 Review recent filings in Kwok case no. 22-

(.7); review related case dockets regarding recent filings (.6); research certain case documents per attorney request (.6) 2.40 565.00 1,356.00 08/06/2024 DM26 Review recent filings in Kwok case no. 22-

(1.2); review related case dockets regarding recent filings (.5); research certain case documents per attorney request (.3) 2.60 565.00 1,469.00 08/07/2024 DM26 Review recent filings in Kwok case no. 22-

(.6); review related case dockets regarding recent filings (.5); research certain case documents per attorney request (.2) 2.10 565.00 1,186.50

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 92 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376

Date Initials Description Hours Rate Amount

08/08/2024 DM26 Review recent filings in Kwok case no. 22-

(.8); review related case dockets regarding recent filings (.5) 1.90 565.00 1,073.50 08/09/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review related case dockets regarding recent filings (.5) 1.80 565.00 1,017.00 08/12/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review related case dockets regarding recent filings (.4); research certain case documents per attorney request (.2) 1.70 565.00 960.50 08/13/2024 DM26 Review recent filings in Kwok case no. 22-

(1.2); review related case dockets regarding recent filings (.4); research certain case documents per attorney request (.2) 2.70 565.00 1,525.50 08/14/2024 DM26 Review recent filings in Kwok case no. 22-

(1.4); review related case dockets regarding recent filings (.5) 2.60 565.00 1,469.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 93 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376

Date Initials Description Hours Rate Amount

08/15/2024 DM26 Review recent filings in certain adversary

update working group re same (.8); review related case dockets regarding recent filings

08/16/2024 DM26 Review recent filings in Kwok case no. 22-

(1.2); review related case dockets regarding recent filings (.4); research certain case documents per attorney request (.2) 2.60 565.00 1,469.00 08/19/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review related case dockets regarding

decisions entered in Kwok's main case and adversary proceedings after 7/28/23 (.3) 1.80 565.00 1,017.00 08/20/2024 DM26 Review recent filings in Kwok case no. 22-

(.6); review related case dockets regarding recent filings (.5); research certain case documents per attorney request (.4) 1.90 565.00 1,073.50 08/21/2024 DM26 Review recent filings in Kwok case no. 22-

(1.1); review related case dockets regarding recent filings (.5); research certain case documents per attorney request (.2) 2.20 565.00 1,243.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 94 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376

Date Initials Description Hours Rate Amount

08/22/2024 DM26 Review recent filings in Kwok case no. 22-

(1.2); review related case dockets regarding recent filings (.5); research certain case documents per attorney request (.2) 2.30 565.00 1,299.50 08/23/2024 DM26 Review recent filings in Kwok case no. 22-

(.8); review related case dockets regarding recent filings (.5); research certain case documents per attorney request (.3) 2.10 565.00 1,186.50 08/26/2024 ML30 Monitor open case dockets (.5); review recent filings and update working group re

(.3); review upcoming deadlines and update working group re same (.1) 1.50 565.00 847.50 08/27/2024 ML30 Monitor open case dockets (.5); review recent filings and update working group re

(.2); review upcoming deadlines and update working group re same (.1) 1.60 565.00 904.00 08/28/2024 ML30 Monitor open dockets in several cases (.5);

group re same (1.2); update case calendars

working group (.2); correspond with E. Sutton re case document needed (.1); research re same (.1) 2.40 565.00 1,356.00 08/29/2024 ML30 Monitor open dockets in several cases (.8);

group re same (.9); update case calendars re

working group (.2) 2.20 565.00 1,243.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 95 of 879

Date Initials Description Hours Rate Amount

08/31/2024 ML30 Monitor open dockets in several cases (.5);

group re same (.5); update case calendars re same (.3); update case deadlines chart for

Subtotal: B113 Pleadings Review 45.00 25,425.00

08/04/2024 ECS1 Review and revise agenda for 8/6/24

regarding same (.1) 0.20 1,270.00 254.00 08/05/2024 DM26 Prepare agenda for 8/6/24 hearing 0.30 565.00 169.50 08/08/2024 DM26 Prepare agenda for 8/13/24 hearing 1.10 565.00 621.50 08/09/2024 DM26 Update agenda for 8/13/24 hearing 0.20 565.00 113.00 08/09/2024 ECS1 Review and revise agenda for 8/13/24

regarding same (.1) 0.20 1,270.00 254.00 08/12/2024 DM26 Update agenda for 8/13/24 hearing 0.20 565.00 113.00 08/18/2024 ECS1 Correspond with D. Mohamed regarding agenda for 8/20 court hearing 0.10 1,270.00 127.00 08/19/2024 DM26 Prepare agenda for hearing scheduled on

08/19/2024 ECS1 Review and revise agenda for 8/20 court

regarding same (.1) 0.20 1,270.00 254.00 08/22/2024 DM26 Prepare agenda for 8/27/24 hearing 0.70 565.00 395.50 08/22/2024 ECS1 Review and revise agenda for 8/27 court

regarding same (.1) 0.20 1,270.00 254.00 08/23/2024 DM26 Update agenda for 8/27/24 hearing 0.20 565.00 113.00

08/27/2024 LAD4 Handle hearing re: mediation procedure 1.10 1,975.00 2,172.50 08/30/2024 ECS1 Prepare agenda for 9/3 court hearing 0.50 1,270.00 635.00 Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 96 of 879

08/13/2024 AB21 Call with C. Edge regarding PH fee

08/13/2024 KAT2 Correspond with E. Sutton regarding July

08/14/2024 AB21 Review PH May fee statement (0.7);

(0.1); correspond with N. Bassett and W. Farmer regarding same (0.1) 0.90 1,850.00 1,665.00 08/14/2024 KAT2 Correspond with E. Sutton regarding July

08/15/2024 AB21 Call with C. Edge regarding PH fee statements (April and May) 0.10 1,850.00 185.00 08/16/2024 KAT2 Review and respond to E. Sutton's fee

08/22/2024 KAT2 Prepare UST Appendix B information for

08/28/2024 DEB4 Correspond with C. Edge regarding fee

Subtotal: B160 Fee/Employment Applications 2.10 3,182.50

B165 Fee/Employment Applications for Other Professionals

08/01/2024 AB21 Correspond with P. Parizek (Kroll) regarding Kroll's notice of rate increase 0.30 1,850.00 555.00

08/03/2024 AB21 Correspond with L. Despins regarding Kroll notice of rate change 0.30 1,850.00 555.00 08/05/2024 AB21 Correspond with P. Parizek (Kroll) regarding Kroll notice of rate increase 0.20 1,850.00 370.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 97 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376

Date Initials Description Hours Rate Amount

08/05/2024 DM26 Revise and file Kroll's notice of change in hourly rates (.2); prepare and effectuate service regarding same (.3) 0.50 565.00 282.50 08/12/2024 AB21 Correspond with D. Hayek (Prager) regarding June and July fee statements (0.1); revise same (0.2); correspond with D.

08/12/2024 DM26 File Prager Dreifuss June and July, 2024

effectuate service regarding same (.3) 0.60 565.00 339.00 08/12/2024 ECS1 Correspond with T. Sadler and L. Song

regarding same (.1) 0.30 1,270.00 381.00 08/12/2024 LS26 Call with E. Sutton re Paramount storage invoice payment (0.1); draft email to L. Despins and N. Bassett regarding same (0.2) 0.30 985.00 295.50 08/13/2024 DM26 File via the Court's CM/ECF system Acheson Doyle's July 2024 invoices (.2);

08/16/2024 AB21 Review NPM May & June fee statement

regarding same (0.1) 0.80 1,850.00 1,480.00 08/16/2024 AB21 Correspond with E. Sutton regarding retention application for real estate broker 0.10 1,850.00 185.00 08/16/2024 ECS1 Prepare Compass retention application

regarding same (.2) 2.20 1,270.00 2,794.00 08/20/2024 AB21 Correspond with L. Despins and E. Sutton

(0.1); call with E. Sutton regarding same

08/20/2024 ECS1 Continue preparing Compass retention

regarding same (.1) 2.30 1,270.00 2,921.00

Date Initials Description Hours Rate Amount

08/20/2024 ECS1 Prepare motion to expedite Compass retention motion (.7); correspond with L. Despins regarding same (.1) 0.80 1,270.00 1,016.00 08/21/2024 ECS1 Continue preparing motion to expedite Compass retention motion (1.1); correspond with L. Despins regarding same

08/21/2024 ECS1 Further prepare Compass/Burke retention

regarding same (.2); correspond with L.

and L. Despins regarding same (.3) 4.40 1,270.00 5,588.00 08/21/2024 LAD4 Review/edit throughout day Compass retention app (1.90); t/c E. Sutton re: same

08/22/2024 ECS1 Prepare retention application for Compass and Julie Burke (2.1); correspond with W. Sherman (NPM), P. Linsey (NPM), and L. Despins regarding same (.7) 2.80 1,270.00 3,556.00 08/22/2024 ECS1 Further prepare motion to expedite Compass retention motion 0.30 1,270.00 381.00 08/23/2024 ECS1 Prepare motion to expedite Compass retention application 0.30 1,270.00 381.00 08/23/2024 ECS1 Prepare retention application for Compass and Julie Burke (.8); correspond with W. Sherman (NPM), P. Linsey (NPM), and L. Despins regarding same (.4) 1.20 1,270.00 1,524.00 08/25/2024 AB21 Correspond with P. Linsey (NPM) regarding Kroll fee statement 0.10 1,850.00 185.00 08/27/2024 ECS1 Correspond with P. Linsey (NPM) and L. Despins regarding retention application for

08/27/2024 ML30 Correspond with E. Sutton re order shortening time re retention application 0.20 565.00 113.00 08/28/2024 ECS1 Correspond with W. Sherman (NPM), P.

retention application for Compass 0.30 1,270.00 381.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 99 of 879

Date Initials Description Hours Rate Amount

08/29/2024 ECS1 Review and prepare schedule of parties in

retention (.2); correspond with L. Despins

(NPM) regarding same (.1) 0.40 1,270.00 508.00 08/29/2024 LAD4 Finalize agreement with real estate broker (1.70); t/c with real estate broker re: same

08/30/2024 ECS1 Revise proposed order on retention

(NPM) regarding same (.2) 0.80 1,270.00 1,016.00 Subtotal: B165 Fee/Employment Applications for

Subtotal: B191 General Litigation 2.20 4,191.00

08/28/2024 LAD4 T/c D. Barron re: auditing firms 0.20 1,975.00 395.00 08/17/2024 NAB Correspond with P. Linsey (NPM) regarding litigation strategy issues 0.20 1,835.00 367.00 08/16/2024 LAD4 Review & edit NPM draft of domain name

08/14/2024 NAB Correspond with L. Despins, P. Linsey

08/02/2024 TS21 Correspond with D. Mohamed and L. Despins re wire for Sciame Homes 0.30 1,365.00 409.50

08/05/2024 AB21 Correspond with T. Sadler regarding wire

Date Initials Description Hours Rate Amount

08/05/2024 DM26 Prepare draft wire transfer regarding Hawk

08/05/2024 TS21 Correspond with A. Bongartz and D. Mohamed re Hawk Eye wire transfer 0.10 1,365.00 136.50 08/06/2024 TS21 Review wire transfer forms for Sciame and Hawk Eye (.3); correspond with L. Despins and A. Bongartz re same (.1) 0.40 1,365.00 546.00 08/07/2024 AB21 Correspond with T. Sadler regarding next

08/07/2024 TS21 Correspond with L. Despins, A. Bongartz, and East West Bank re wires (.2); correspond with L. Despins and A. Bongartz re UST quarterly fees (.1) 0.30 1,365.00 409.50 08/08/2024 AB21 Correspond with T. Sadler re U.S. Trustee

(U.S. Trustee) regarding same (0.3) 0.40 1,850.00 740.00 08/11/2024 AB21 Correspond with T. Sadler regarding upcoming wire transfers 0.10 1,850.00 185.00 08/12/2024 AB21 Correspond with T. Sadler regarding Acheson wire transfer 0.10 1,850.00 185.00 08/12/2024 DM26 Prepare draft wire transfer regarding invoice of Hawk Eye Security 0.10 565.00 56.50 08/12/2024 TS21 Correspond with L. Despins and D. Mohamed re Hawk Eye wire transfer 0.10 1,365.00 136.50 08/13/2024 DM26 Prepare draft wire transfers for The Sherry Netherland and Acheson Doyle 0.20 565.00 113.00 08/20/2024 AB21 Correspond with T. Sadler regarding security firm wire transfer 0.10 1,850.00 185.00 08/20/2024 TS21 Correspond with D. Mohamed re Paramount wire transfer 0.50 1,365.00 682.50 08/21/2024 DM26 Prepare draft wire transfers regarding

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 101 of 879 Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376

Date Initials Description Hours Rate Amount

08/21/2024 DEB4 Conference with T. Sadler regarding payments related to real properties (0.1);

(0.2); correspond with L. Despins regarding

08/21/2024 TS21 Review wire transfer forms for Acheson

regarding same (.1); correspond with L. Despins and East West Bank re same (.2) 1.00 1,365.00 1,365.00 08/23/2024 TS21 Correspond with Neubert Pepe re tax and insurance payments 0.70 1,365.00 955.50 08/27/2024 TS21 Correspond with East West Bank, L.

08/29/2024 TS21 Correspond with L. Despins, D. Barron and

Subtotal: B210 Business Operations 6.80 9,090.50 B211 Financial Reports (Monthly Operating Reports) 08/20/2024 DEB4 Correspond with T. Sadler regarding MOR 0.50 1,395.00 697.50

Subtotal: B211 Financial Reports (Monthly

08/21/2024 TS21 Correspond with D. Barron, L. Despins and

report (.4); revise monthly operating report

08/21/2024 DEB4 Correspond with T. Sadler regarding MOR 0.10 1,395.00 139.50 08/21/2024 DM26 File monthly operating report for period

08/20/2024 TS21 Prepare July MOR (1.8); correspond with D. Barron re same (.3) 2.10 1,365.00 2,866.50 Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 102 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376 Page 17

Date Initials Description Hours Rate Amount

B310 Claims Administration and Objections

AB21 date notice Correspond with D. Barron regarding bar 0.10 1,850.00 185.00 Subtotal:

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 10.40 1,975.00 20,540.00 NAB Nicholas A. Bassett Partner 5.50 1,835.00 10,092.50 AB21 Alex Bongartz Of Counsel 4.90 1,850.00 9,065.00 KAT2 Katherine A. Traxler Of Counsel 0.90 1,120.00 1,008.00 DEB4 Douglass E. Barron Associate 4.80 1,395.00 6,696.00 TS21 Tess Sadler Associate 7.50 1,365.00 10,237.50 ECS1 Ezra C. Sutton Associate 19.30 1,270.00 24,511.00 LS26 Luyi Song Associate 2.70 985.00 2,659.50 ML30 Mat Laskowski Paralegal 11.90 565.00 6,723.50 DM26 David Mohamed Paralegal 54.40 565.00 30,736.00

Date Description Quantity Rate Amount

08/05/2024 Photocopy Charges 80.00 0.08 6.40 08/12/2024 Photocopy Charges 340.00 0.08 27.20 08/13/2024 Photocopy Charges 200.00 0.08 16.00 08/23/2024 Photocopy Charges 800.00 0.08 64.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 103 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 18

(USD)(JPMPCARD); Invoice # 843401798; 02/20/2024; c/o CT Corporation System; Pillsbury Winthrop Shaw Pittman; 1015 15th St. NW;

(USD)(JPMPCARD); Invoice # 843401798; 02/23/2024; Joe Halbardier; Shaylen Music LLC; 1900 Ave of the Stars 25th Fl; LOS ANGELES, CA

(USD)(JPMPCARD); Invoice # 843401798; 02/27/2024; George Gobble; Jamestown Associates LLC; 6770 E Edgemont St; TUCSON, AZ 85710 ;

(USD)(JPMPCARD); Invoice # 843401798;

(USD)(JPMPCARD); Invoice # 843401798;

Mitchell LLC; 55 MADISON AVE STE 400;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Officer Managing or General Agent; OSC Orbit Service Company LLC; 101 Merritt 7 Corporate Place; NORWALK, CT 06851 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Marcum LLP Goodwin Square; c/o Corporation Service Company; 225 Asylum 20th Fl.; HARTFORD, CT 06103 ; 271634271755 (MAN) 21.09

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 19

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Cirrus Design Corporation; c/o Registered Agent Solutions; 100 Wilburn Rd Ste 100; SUN PRAIRIE, WI 53590 ; 271632210224

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Officer Managing or General Agent; Marcum LLP; 10 Melville Park Rd; MELVILLE,

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Nicholas Paindiris; OSC Orbit Service Company LLC; 2252 Main Street;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Officer Managing or General Agent; Cirrus Design Corporation; 4515 Taylor Circle; DULUTH, MN 55811 ; 271627419684 (MAN) 21.09

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Cirrus Design Corporation; c/o Registered Agent Solutions; 222 S. 9th Street Suite 450; MINNEAPOLIS, MN 55402 ; 271631969825

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Robert E. Molloy; Sedgwick Realty Corp.; 525 W Homer #401; CHICAGO, IL 60622 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Jocelyn Kuo; Paul Hastings; 200 Park Avenue; NEW YORK, NY 10166 ; 580016412314

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 105 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 20

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; ; Cayuse Government Services LL; 112 North Curry Street; CARSON CITY, NV 89703 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Officer Managing or General Agent; 9 East 40th Street LLC c/o Woh; 10 East 40th Street 3203; NEW YORK CITY, NY 10016 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Sedgwick Realty Corp.; c/o C T Corporation System; 28 Liberty St.; NEW YORK,

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Officer Managing or General Agent; Petrillo Klein & Boxer LLP; 655 Third Avenue 22nd Floor; NEW YORK, NY 10017 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Officer Managing or General Agent; Marcum LLP; 730 3rd Avenue 11th floor; NEW YORK, NY 10017 ; 271629769852 (MAN) 23.42

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Brune Law PC c/o CT Corp Systems; 28 Liberty St.; NEW YORK, NY 10005 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Officer Managing or General Agent; Brune Law PC; 450 Park Avenue Suite 1901; NEW YORK, NY 10022 ; 271626649150 (MAN) 23.42

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 106 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 21

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Dawn Hagen; Cayuse Government

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; OSC Orbit Service Company LLC; c/o Registered Agents Inc.; 418 Broadway Ste R; ALBANY, NY 12207 ; 271634875985 (MAN) 25.85

(USD)(JPMPCARD); Invoice # 843401798;

Corporation; 8504 Gaither Hollow Ct.; ELLICOTT CITY, MD 21043 ; 271627948170 (MAN) 28.32

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Tao Zheng; 3760 Bird Rd Unit 704; MIAMI, FL 33146 ; 271631063292 (MAN) 28.32

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Officer Managing or General Agent; Gypsy Mei Food Services LLC; 600 Mamaroneck Avenue #400; HARRISON, NY 10528 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Tao Zheng; 1200 Frank E Rodgers Blvd S; HARRISON, NJ 07029 ; 271635381001

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Gypsy Mei Food Services LLC; c/o Corporate Creations Network; 600 Mamaroneck Avenue #400; HARRISON, NY 10528 ;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 22

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Jason Miller; 2305 N. Lincoln Street; ARLINGTON, VA 22207 ; 271629271848 (MAN) 28.32

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Officer Managing or General Agent; Sedgwick Realty Corp.; 15 Close Rd; GREENWICH, CT 06831 ; 271630807313 (MAN) 28.32

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Nicholas Paindiris; OSC Orbit Service Company LLC; 119 Butler Drive;

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Feng Yi; 157 Rajkovich Way; SAN JOSE, CA 95120 ; 271628387626 (MAN) 28.87

(USD)(JPMPCARD); Invoice # 843401798; 03/01/2024; Mei Guo; 492 Broome St Apt 3; NEW YORK, NY 10013 ; 271629936205 (MAN) 31.76

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Jocelyn Kuo; Paul Hastings LLP; 200 Park Avenue; NEW YORK, NY 10166 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Officer Managing or General Agent; NAV Consulting Inc.; 1 Trans Am Pla a Drive Suite; VILLA PARK, IL 60181 ; 271721148220

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; River Valley Operations LLC; c/o Registered Agents Inc; 5534 Saint Joe Road; FORT WAYNE, IN 46835 ; 271719752550 (MAN) 21.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 108 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 23

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Officer Managing or General Agent; Flying Colours Corp; 525 Turbine Ave;

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Gettr USA Inc. Corp. Trust Ce; c/o The Corporation Trust Company; 1209 Orange Street; WILMINGTON, DE 19801 ; 271723480934

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Jared Scott Thomson; River Valley Operations LLC; 1851 West Henri De Tonti Blvd; SPRINGDALE, AR 72762 ; 271722501653 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; return; paul hastings 200; 200 park avenue; NEW YORK, NY 10166 ; 653687408846

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Officer Managing or General Agent; WA & HF LLC; 1621 114 Avenue SE Suite 105; BELLEVUE, WA 98004 ; 271717683359 (MAN) 21.55

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Top California Beach Corp.; 7940 Garvey Ave Ste 202; ROSEMEAD, CA 91770 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Gary Kurt; Dark Shadows LLC; 30101 Agoura Ct #118; AGOURA HILLS, CA 91301 ;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 24

(USD)(JPMPCARD); Invoice # 843401798;

STATE ST; ALBANY, NY 12207 ; 713409278240

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Officer Managing or General Agent; Quick-Equip LLC; 1410 Broadway Suite 1202; NEW YORK, NY 10018 ; 271721567190 (MAN) 23.32

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Gettr USA Inc.; c/o C T Corporation System; 28 Liberty Street; NEW YORK, NY 10005

(USD)(JPMPCARD); Invoice # 843401798;

Management Service; 160 Middle Road;

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Chris Lee; Top California Beach Corp.; 2436 Park Blvd; UPLAND, CA 91784 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Antonio Forteleoni; Curiosity Corp. LLC; 1344 Belfast Dr.; WEST HOLLYWOOD, CA

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Duoyue Wang; WA & HF LLC; 7419 W Mercer Way; MERCER ISLAND, WA 98040 ;

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 110 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 25

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Anthony DiBattista; 45 Park Hill Drive; HOPEWELL JUNCTION, NY 12533 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/04/2024; Officer Managing or General Agent; Gettr USA Inc.; 3 COLUMBUS CIRCLE 20TH; NEW YORK, NY 10019 ; 271720564622 (MAN) 45.82

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Lexington Property and Staffin; c/o Corporation Service Compan; 251 Little Falls Drive;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; HCHK Property Management Inc.; c/o The Corporation Trust Comp; 1209 Orange Street; WILMINGTON, DE 19805 ; 271781130875

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; HCHK Property Management Inc.; c/o Corporation Service Compan; 80 State Street; ALBANY, NY 12207 ; 271769212455 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; GF Italy LLC Corp. Trust Cente; c/o The Corporation Trust Comp; 1209 Orange St;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Hayman Hong Kong Opportunitie; Opportunities Onshore Fund LP; 251 Little Falls Drive; WILMINGTON, DE 19808 ; 271779358726

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 26

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; c/o Registered Agents Inc; Rule of Law Society IV Inc.; 1717 N Street NW Suite 1;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Llija Pavlovic; Crocker Mansion Estate LLC; 19 Spear Road Suite 306; RAMSEY, NJ 07446

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; HCHK Property Management Inc; Princeton South Corporate Cent; 100 Charles Ewing Blvd Suite 1; TRENTON, NJ 08628 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; c/o The Corporation Trust Comp; GFNY Inc; 1209 N ORANGE ST;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Himalaya New World Inc.; 12587 Fair Lakes Circle

(USD)(JPMPCARD); Invoice # 843401798;

Corporation System; 820 Bear Tavern Road; TRENTON, NJ 08628 ; 271767721575 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Lexington Property and Staffin; c/o Corporation Service Compan; 80 State Street; ALBANY, NY 12207 ; 271781772293 (MAN) 21.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 112 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 27

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Crocker Mansion Estate LLC; 17 Spear Road; RAMSEY, NJ 07446 ; 271765717639 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Yanming Wang Spices Inc.; Omicron Nutraceutical LLC; 82 Wendel Ave Ste 100; PITTSFIELD, MA 01201 ; 271777129489 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798;

Corporation Service Compan; 80 State Street; ALBANY, NY 12207 ; 271769050370 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; James Moriarty c/o Zeisler & Z; Leading Shine NY Ltd.; 10 Middle Street Floor 15; BRIDGEPORT, CT 06604 ; 271783883149 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Leading Shine NY Ltd.; c/o Corporate Creations Networ; 3411 Silverside Road Suite 10;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; c/o The Corporation Trust Comp; Rule of Law Society IV Inc.; 1209 Orange St;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Mountains of Spices Inc.; 8 The Green Suite A; DOVER, DE 19901 ; 271762093665 (MAN) 21.00

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 28

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Mountains of Spices Inc.; c/o A Registered Agent Inc.; 8 The Green Ste A; DOVER,

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Omicron Nutraceutical LLC; 82 Wendel Avenue Suite 100; PITTSFIELD, MA 01201 ;

(USD)(JPMPCARD); Invoice # 843401798;

Corporation Service Compan; 251 Little Falls Drive;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; James Moriarty Hudson Diamond; NY LLC / Zeisler & Zeisler P.; 10 Middle Street Floor

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; G Club Holdco I Corp Trust Cen; c/o The Corporation Trust Comp; 1209 Orange St;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; c/o The Corporation Trust Comp; Rule of Law Foundation III Inc; 1209 Orange St.;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 29

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Stuart Smith Hayman Hong; Kong Opportunities Onshore Fun; 3889 Maple Avenue 6th Floor; DALLAS, TX 75219 ; 271767414277

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; MOS Himalaya Foundation Inc.; 1129 Northern Blvd. Suite 404; MANHASSET, NY 11030 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Lura Barua; Taurus Fund LLC / GG Internat; 6628 Sky Pointe Dr. Ste 129; LAS VEGAS, NV 89131 ; 271778850365 (MAN) 21.55

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Taurus Fund LLC; 6628 Sky Pointe Drive Ste 129; LAS VEGAS, NV 89131 ; 271766103584 (MAN) 21.55

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; c/o Greenberg Traurig LLP; GFNY

ANGELES, CA 90067 ; 271785128208 (MAN) 21.55

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Golden Spring (New York) Limi; c/o C T Corporation System; 28 Liberty St.; NEW YORK, NY 10005 ; 271779747237 (MAN) 23.32

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent;

YORK, NY 10019 ; 271770956387 (MAN) 23.32

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 115 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 30

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Xuebing Wang Victor Cerda; Rule of Law Foundation III Inc; 57 W 57th St Ste 400; NEW YORK, NY 10019 ; 271782413259 (MAN) 23.32

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Anthony DiBattista; Lexington Property and Staffin; 750 Lexington Ave. 8th Fl; NEW YORK, NY 10022 ; 271769370303 (MAN) 23.32

(USD)(JPMPCARD); Invoice # 843401798;

Technologies Inc.; 750 Lexington Avenue; NEW YORK, NY 10022 ; 271780163907 (MAN) 23.32

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Rule of Law Society IV Inc.; 57 West 57th Street Suite 400; NEW YORK, NY 10019 ; 271784179360

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Rule of Law Foundation III Inc; 57 West 57th Street Suite 400; NEW YORK, NY 10019 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Scott Barnett; Taurus Fund LLC; 218 Elsie Avenue; MERRICK, NY 11566 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Greenwich Land LLC; 169 Rockingstone Avenue; LARCHMONT, NY 10538 ; 271779972601 (MAN) 28.20

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 116 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 31

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Himalaya Shanghai Farm LLC; 12 Lara Lane;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Hing Chi Ngok; Greenwich Land LLC; 373 Taconic Road; GREENWICH, CT 06831

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Bingshang Jiao Spices Inc.; Himalaya New World Inc.; 2901 Brians Hill Ln; OAKTON,

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Zhang Xianhong Spices Inc.; Himalaya Boston Mayflower LLC; 3513 NE 171 ST; NORTH MIAMI BEACH, FL 33160 ; 271777346075 (MAN) 28.20

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Himalaya New York Rock; 301 West Street Apt 8E;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Himalaya Boston Mayflower LLC; 3513 NE 171 Street; NORTH MIAMI BEACH, FL 33160 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Xiaohong Peng; Himalaya Shanghai

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 32

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Himalaya New York Rock; 301 W 110 Street Apt 8E; NEW YORK CITY, NY 10026 ; 271777930164

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Fanggui Zhu; None; 2717 Cedar St. Unite B; EVERETT, WA 98201 ; 271766800985

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Weihua Li; None; 2377 Clubhouse Dr; ROCKLIN, CA 95765 ; 271766338996 (MAN) 28.75

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; G

ANGELES, CA 90046 ; 271761869596 (MAN) 28.75

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Leanne Li; G Club Three; 800 N Harper Ave; LOS ANGELES, CA 90046 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Shiying Li; None; 1128 Curtner Ave; SAN JOSE, CA 95125 ; 271766994054 (MAN) 28.75

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; c/o Mei Guo; Leading Shine NY Ltd.; 492 Broome St Apt 3; NEW YORK, NY 10013 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; c/o Mei Guo; Hudson Diamond NY

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 33

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent;

4TH FL; NEW YORK, NY 10065 ; 271779536635

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent;

CIRCLE; NEW YORK, NY 10019 ; 271769577645

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Yanping Wang; Golden Spring (New York) Limit; 57 WEST 57TH STREET SUITE 400; NEW YORK, NY 10019 ; 271768061040 (MAN) 45.82

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; [Adv. Proc. No. 24-05275]; GFNY

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; G Club Holdco I LLC; 1 COLUMBUS CIRCLE; NEW YORK, NY 10019 ; 271761527341 (MAN) 45.82

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Leading Shine NY Ltd.; 57 WEST 57TH STREET SUITE 400; NEW YORK, NY 10019 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Rule of Law Society IV Inc.; 57 WEST 57TH STREET SUITE 400; NEW YORK, NY 10019 ;

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 119 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 34

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Saraca Media Group Inc.; 1 COLUMBUS CIRCLE; NEW YORK, NY 10019 ; 271771579177 (MAN) 45.82

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Ping Tang or Michael Baranowit; Rule of Law Society IV Inc; 1 COLUMBUS CIRCLE; NEW YORK, NY 10019 ; 271783569798 (MAN) 45.82

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Leading Shine NY Ltd.; 1 COLUMBUS CIRCLE; NEW YORK, NY 10019 ; 271769744465 (MAN) 45.82

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; G

CIRCLE; NEW YORK, NY 10019 ; 271770329230

(USD)(JPMPCARD); Invoice # 843401798; 03/05/2024; Officer Managing or General Agent; Rule of Law Foundation III Inc; 57 WEST 57TH STREET SUITE 400; NEW YORK, NY 10019 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; jocelyn kuo; paul hastings; 200 park

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; GF Italy LLC Corp. Trust Cent; c/o The Corporation Trust Comp; 1209 Orange St.;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 35

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

Corporate Place 3rd Floor; NORWALK, CT 06851

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Victor Cerda; Victor Cerda; 411 Theodore Fremd Avenue Sui; RYE, NY 10580 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

Street; NEW YORK, NY 10065 ; 271823585953

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; GETTR USA INC. Corp. Trust Ce; c/o The Corporation Trust Comp; 1209 Orange St;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Nicholas Paindiris; O.S.C. ORBIT SERVICE COMPANY L; 2252 Main Street;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

64th Street; NEW YORK, NY 10065 ;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 36

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o The Corporation Trust Comp;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o The Corporation Trust Comp;

Orange St.; WILMINGTON, DE 19801 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o REGISTERED AGENTS INC.;

(USD)(JPMPCARD); Invoice # 843401798;

LLC; c/o Corporate Creation Network; 1521

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Yongbing Zhang; Yongbing Zhang; 67 East Madison Street Suite; CHICAGO, IL 60603 ;

(USD)(JPMPCARD); Invoice # 843401798;

Trust Comp; 1209 Orange Street; WILMINGTON,

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 122 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 37

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent; GTV MEDIA GROUP INC.; 162 East 64th Street; NEW YORK, NY 10065 ; 271820697939 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Alex Hadjicharalambous;

Street; LONG ISLAND CITY, NY 11105 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; GS SECURITY SOLUTIONS INC; c/o Registered Agents Inc.; 5 Greentree Centre 525 Route 7; MARLTON, NJ 08053 ; 271820487634

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Registered Agents Inc.; O.S.C.

(USD)(JPMPCARD); Invoice # 843401798;

Service Compan; 251 Little Falls Dr.;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; SARACA MEDIA GROUP INC.; SARACA MEDIA GROUP INC.; 162 E 64th St; NEW YORK, NY 10065 ; 271831506674 (MAN) 21.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 123 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 38

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; GFNY INC. Corporation Trust C; c/o The Corporation Trust Comp; 1209 Orange St;

(USD)(JPMPCARD); Invoice # 843401798;

LLC; c/o Corporate Creations Networ; 1521

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Corporation Service Compan;

Little Falls Drive; WILMINGTON, DE 19808 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; G Club US Operations LLC G Mus; c/o Corporation Service Compan; 251 Little Falls Drive; WILMINGTON, DE 19808 ; 271815646880

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; GF IP LLC Corp. Trust Center; c/o The Corporation Trust Comp; 1209 Orange St.;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Yanping Yvette Wang; Carl Gulliver

HAVEN, CT 06513 ; 271834812622 (MAN) 21.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 124 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 39

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Crane Advisory Group L.L.C.; United States Corporation Agen; 7014 13th Avenue Suite

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

East 64th Street; NEW YORK, NY 10065 ;

(USD)(JPMPCARD); Invoice # 843401798;

NOT SUPPLIED; 55 Madison Avenue 4th Floor;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o The Corporation Trust Comp; SEVEN MISSION GROUP LLC; 1209 Orange St.;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; James Moriarty; c/o Zeisler & Zeisler P.C.; 10 Middle Street Floor 15; BRIDGEPORT,

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Yongbing Zhang; Yongbing Zhang; 223 West Jackson Blvd. Suite; CHICAGO, IL

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 125 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 40

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; GNEWS MEDIA GROUP INC. GFNY I; c/o Corporate Creation Network; 1521

(USD)(JPMPCARD); Invoice # 843401798;

NOT SUPPLIED; 920 Belmont Avenue Apt 3104; HALEDON, NJ 07508 ; 271811656809 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; James Moriarty; LEADING SHINE NY LTD.; 10 Middle Street Floor 15; BRIDGEPORT, CT 06604 ; 271824527052 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Corporation Service Compan;

State Street; ALBANY, NY 12207 ; 271824974975

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

Avenue 4th Floor; MORRISTOWN, NJ 07960 ;

(USD)(JPMPCARD); Invoice # 843401798;

Corporation Service Compan; 251 Little Falls Drive;

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 126 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 41

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

Street; NEW YORK, NY 10065 ; 271823831079

(USD)(JPMPCARD); Invoice # 843401798;

DIAMOND NY LLC; 10 Middle Street Floor 15; BRIDGEPORT, CT 06604 ; 271821962766 (MAN) 21.00

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Registered Agents Inc.; RULE OF

STE 1; WASHINGTON, DC 20036 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Howard Steinberg GFNY INC.; c/o Greenberg Traurig LLP.; 1840 Century Park East Suite; LOS ANGELES, CA 90067 ; 271819142144

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Lura Barua; TAURUS FUND LLC;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; GFASHION MEDIA GROUP INC.; c/o Corporate Creations Networ; 5901 W. Century Blvd. #750; LOS ANGELES, CA 90045 ;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 42

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Howard Steinberg G Music LLC; c/o Greenberg Traurig LLP; 1840 Century Park East Suite; LOS ANGELES, CA 90067 ; 271815021240

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; G Fashion (CA); c/o Summer Bridges; 1245 Factory Place; LOS ANGELES, CA 90013 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

POINTE DR; LAS VEGAS, NV 89131 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent; G

ANGELES, CA 90013 ; 271814322823 (MAN) 21.55

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Aaron Mitchell; GETTR USA INC c/o Weddle Law; 37 West 20th Street Suite 120; NEW YORK CITY, NY 10011 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 43

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Louis M. Freeman; MAX KRASNER; 75 Maiden Lane Suite 503; NEW YORK CITY, NY

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent; G Fashion (CA); 590 Madison Ave; NEW YORK, NY

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Anthony DiBattista; LEXINGTON PROPERTY AND STAFFIN; 750 Lexington Ave. 8TH FL; NEW YORK, NY 10022 ; 271825163251

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Corporation Service Compan;

BROADWAY ST; HOBBS, NM 88240 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent; G Club US Operations LLC; 590 Madison Avenue; NEW YORK, NY 10022 ; 271815898449 (MAN) 23.32

(USD)(JPMPCARD); Invoice # 843401798;

Corporation System; 28 Liberty Street; NEW YORK, NY 10005 ; 271816075052 (MAN) 23.32

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 44

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent; Crane Advisory Group L.L.C; One World Trade Center 85th F; NEW YORK, NY 10007 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Hing Chi Ngok GFNY INC.; GREENWICH LAND LLC; 373 Taconic Road; GREENWICH, CT 06831 ; 271819716522 (MAN) 28.20

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Scott Barnett; Scott Barnett; 218 ELSIE AVE; MERRICK, NY 11566 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

AVENUE STE 21F; NEW YORK, NY 10065 ;

(USD)(JPMPCARD); Invoice # 843401798;

NOT SUPPLIED; 373 Taconic Road; GREENWICH, CT 06831 ; 271822851328 (MAN) 28.20

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Max Krasner; Max Krasner; 20 Stacey Ln; STATEN ISLAND, NY 10306 ; 271826277338

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Scott Barnett; TAURUS FUND LLC; 218 ELSIE AVE; MERRICK, NY 11566 ;

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 130 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 45

(USD)(JPMPCARD); Invoice # 843401798;

III IN; 800 5TH AVE APT 21F; NEW YORK, NY

(USD)(JPMPCARD); Invoice # 843401798;

NOT SUPPLIED; 16 Princeton Drive; HUNTINGTON STATION, NY 11746 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Nicholas Savio; Nicholas Savio; 63 New Jersey Ave.; OCEAN GROVE, NJ 07756 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

Suite 21F; NEW YORK, NY 10065 ; 271824061948

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Karin Maistrello; Karin Maistrello; 17 Gifford Ave Apt 5F; JERSEY CITY, NJ 07304 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 131 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 46

(USD)(JPMPCARD); Invoice # 843401798;

Brompton Rd; GREAT NECK, NY 11021 ;

(USD)(JPMPCARD); Invoice # 843401798;

ISLAND CITY, NY 11101 ; 271811356720 (MAN) 28.20

(USD)(JPMPCARD); Invoice # 843401798;

Thornley Pl; HOLMDEL, NJ 07733 ;

(USD)(JPMPCARD); Invoice # 843401798;

NOT SUPPLIED; 373 Taconic Road; GREENWICH, CT 06831 ; 271811792648 (MAN) 28.20

(USD)(JPMPCARD); Invoice # 843401798;

BERGEN, NJ 07047 ; 271811522896 (MAN) 28.20

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Haitham Khaled; Crane Advisory Group L.L.C.; 16 Princeton Drive; HUNTINGTON STATION, NY 11746 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Victor Cerda; Victor Cerda; 17 Jean St; RYE, NY 10580 ; 271834094984 (MAN) 28.20

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 132 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 47

(USD)(JPMPCARD); Invoice # 843401798;

Summit Pl; STATEN ISLAND, NY 10312 ;

(USD)(JPMPCARD); Invoice # 843401798;

Greenberg Traurig LLP.; 102-21 63rd Rd Apt. 64A; FLUSHING, NY 11375 ; 271819270114 (MAN) 28.20

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Officer Managing or General Agent;

GROVE, NJ 07756 ; 271832047666 (MAN) 28.20

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Qidong Xia; Qidong Xia; 7552 113th St. Apt 2F; FLUSHING, NY 11375 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Yongbing Zhang; None; 83 Fabish Ct;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Nicholas Savio; Nicholas Savio; 3 Dale Court; HAZLET, NJ 07730 ; 271827136147 (MAN) 28.20

(USD)(JPMPCARD); Invoice # 843401798;

MANAGEMENT LLC; 218 ELSIE AVE; MERRICK, NY 11566 ; 271833362752 (MAN) 28.20

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 48

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Jessica Mastrogiovanni;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Aaron Mitchell; GTV MEDIA

(USD)(JPMPCARD); Invoice # 843401798;

YORK, NY 10013 ; 271822063032 (MAN) 31.63

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Jessica Mastrogiovanni; Jessica Mastrogiovanni; 504 Grand St. Apt H31; NEW YORK, NY 10002 ; 271822495360 (MAN) 31.63

(USD)(JPMPCARD); Invoice # 843401798;

(USD)(JPMPCARD); Invoice # 843401798;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Mei Guo; Mei Guo; 492 Broome St Apt. 3; NEW YORK, NY 10013 ; 271826690510

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Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 49

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Anthony Dibattista; INFORMATION NOT SUPPLIED; 45 Park Hill Drive; HOPEWELL JUNCTION, NY 12533 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; c/o Aaron Mitchell; GETTR USA INC.; 21 Willow Dr.; CHESTER, NJ 07930 ;

(USD)(JPMPCARD); Invoice # 843401798;

(USD)(JPMPCARD); Invoice # 843401798;

MITCHELL LLC; 55 MADISON AVE STE 400;

(USD)(JPMPCARD); Invoice # 843401798; 03/06/2024; Max Krasner; Max Krasner; 6THORNLEY PL; HOLMDEL, NJ 07733 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/07/2024; Jocelyn Kuo; Paul Hastings LLP; 200 Park Avenue; NEW YORK, NY 10166 ;

(USD)(JPMPCARD); Invoice # 843401798; 03/07/2024; Jocelyn Kuo; Paul Hastings LLP; 200 Park Avenue; NEW YORK, NY 10166 ;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 50

463-11058 Dated 04/08/24, FedEx courier services;

08/01/2024 Computer Search (Other) 13.86

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 100 dated 08/11/2024; Douglass Barron; Dinner; Restaurant: Evergreen on 38; Number of People: 1;

08/02/2024 Computer Search (Other) 37.98

08/03/2024 Computer Search (Other) 6.30

08/04/2024 Computer Search (Other) 5.40

08/05/2024 Computer Search (Other) 25.38

08/06/2024 Computer Search (Other) 49.77 08/07/2024 Computer Search (Other) 9.27 08/08/2024 Computer Search (Other) 18.00 08/09/2024 Computer Search (Other) 6.12 08/10/2024 Computer Search (Other) 7.74 08/11/2024 Computer Search (Other) 3.96

08/12/2024 Computer Search (Other) 10.62 Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 136 of 879

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2429376 Page 51

Total Costs incurred and advanced \$7,263.20 08/28/2024 Computer Search (Other) 6.66

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 102 dated 09/08/2024; Douglass Barron; Location: New York; Kwok; Order # 801027237575743 dated

08/24/2024 Computer Search (Other) 0.36 08/23/2024 Computer Search (Other) 21.24

08/22/2024 Computer Search (Other) 17.10 08/21/2024 Computer Search (Other) 89.28 08/20/2024 Computer Search (Other) 9.90

08/19/2024 Computer Search (Other) 10.35 08/18/2024 Computer Search (Other) 6.66

08/17/2024 Computer Search (Other) 16.29 08/16/2024 Computer Search (Other) 12.42 08/14/2024 Computer Search (Other) 15.48

International;

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 137 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$220,884.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 138 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$220,884.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 139 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho February 7, 2025

New York, NY 10166 Invoice Number: 2429377

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending August 31, 2024 Asset Recovery Investigation and Litigation \$220,884.00

Date Initials Description Hours Rate Amount

08/01/2024 DM26 Review returned mail from service of

08/01/2024 ECS1 Analyze issues regarding service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings (.2);

regarding same (.2); correspond with K. Mitchell (NPM) regarding same (.2) 0.60 1,270.00 762.00 08/02/2024 DM26 Update appeals tracking chart 0.30 565.00 169.50 08/02/2024 DEB4 Review draft response to Cerda motion to

regarding same (0.3); correspond with L. Song regarding entity transfers (0.1); analyze

(0.5); correspond with N. Bassett regarding

08/02/2024 ECS1 Review issues related to service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings 0.10 1,270.00 127.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 140 of 879

Date Initials Description Hours Rate Amount

08/02/2024 NAB Correspond with W. Farmer regarding

08/03/2024 DEB4 Correspond and conference with P. Linsey

transfer issues (0.8); correspond with L.

potential alter egos (0.4) 1.20 1,395.00 1,674.00 08/03/2024 NAB Review draft stipulation for stay of state court litigation against Taurus Fund (.3);

08/06/2024 DM26 Review and update tracker regarding

08/06/2024 ECS1 Review issues regarding service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings (.1);

regarding same (.1); correspond with K. Mitchell (NPM) regarding same (.1) 0.30 1,270.00 381.00 08/08/2024 ECS1 Review issue regarding service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings (.1);

regarding same (.1) 0.20 1,270.00 254.00 08/09/2024 AB21 Correspond with L. Despins regarding

(0.4);

regarding same (0.2) 0.60 1,850.00 1,110.00 08/09/2024 DM26 Prepare spreadsheet regarding defendants in certain adversary proceedings related to the debtor (1.1); update appeals tracking chart

08/09/2024 DEB4 Correspond with A. Lomas and J. Lazarus regarding new alter egos (0.4); correspond with T Sono reastding same (01) 0.50 1,395.00 697.50

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 141 of 879 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

Date Initials Description Hours Rate Amount

08/12/2024 ECS1 Review issue regarding service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings (.1);

regarding same (.1) 0.20 1,270.00 254.00 08/12/2024 KC27 Correspond with D. Barron regarding case findings re personal jurisdiction 0.10 1,185.00 118.50 08/13/2024 AB21 Correspond with P. Linsey (NPM)

tolling agreement (0.1); call with E. Sutton regarding same (0.1) 0.20 1,850.00 370.00 08/15/2024 AB21 Correspond with A. Thorp (Harneys Legal) regarding monitoring BVI entities (0.3); prepare related list (0.2); call with D. Barron regarding list of Cayman Island entities (0.1) 0.60 1,850.00 1,110.00 08/15/2024 DEB4 Conference with A. Bongartz regarding potential Cayman insolvency filing 0.10 1,395.00 139.50 08/15/2024 DEB4 Correspond with K. Liu regarding Hong Kong company information 0.20 1,395.00 279.00 08/15/2024 ECS1 Analyze issues regarding service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings 0.50 1,270.00 635.00 08/16/2024 DEB4 Correspond with P. Linsey (NPM) regarding upcoming filings (0.1);

litigation issues/task list (0.1); correspond with L. Song regarding evidentiary issues

08/16/2024 ECS1 Analyze service of foreign defendants in

(.5); correspond with N. Bassett, W. Farmer and P. Linsey (NPM) regarding same (.3) 0.80 1,270.00 1,016.00 08/19/2024 DM26 Update appeals tracking chart 0.30 565.00 169.50

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 142 of 879 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

Date Initials Description Hours Rate Amount

08/19/2024 ECS1 Analyze service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings (.4); correspond with E. Ring (Ancillary) regarding same (.2);

regarding same (.1) 0.70 1,270.00 889.00 08/19/2024 NAB Review appellate brief in discovery

regarding tolling stipulation 0.10 1,850.00 185.00 08/20/2024 ECS1 Analyze service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings (.4); correspond with E. Ring (Ancillary) regarding same (.1); correspond with P. Linsey (NPM) and K. Mitchell (NPM) regarding same (.4);

08/22/2024 DEB4 Correspond with A. Thorp (Harneys Legal) regarding BVI issues (0.1); correspond with

motions for default judgment (0.4); analyze documents related to same (0.5) 1.00 1,395.00 1,395.00 08/23/2024 DEB4 Correspond with A. Thorp regarding BVI filings (0.1); correspond with L. Despins regarding jurisdiction issues (0.3) 0.40 1,395.00 558.00 08/23/2024 KC27 Correspond with D. Barron re personal jurisdiction issues 1.50 1,185.00 1,777.50 08/24/2024 DEB4 Correspond with P. Linsey (NPM) regarding upcoming deadlines (0.1);

Mishcon de Reya (0.1); correspond with N. Bassett regarding alter ego issues (0.2);

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 143 of 879

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 144 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

Date Initials Description Hours Rate Amount

08/29/2024 DEB4 Correspond with E. Sutton regarding UK service issues (0.4); correspond with L. Despins regarding same (0.1) 0.50 1,395.00 697.50 08/29/2024 ECS1 Analyze service of omnibus alter ego

procedure (.3); correspond with D. Barron regarding same (.3); correspond with G. Selva regarding same (.3) 0.90 1,270.00 1,143.00 08/29/2024 ECS1 Analyze issues regarding service of foreign

omnibus alter ego proceedings (.5);

regarding same (.2); correspond with K. Mitchell (NPM) regarding same (.2);

08/30/2024 ECS1 Review issues regarding service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings 0.10 1,270.00 127.00 08/30/2024 ECS1 Analyze issues regarding service of foreign defendants in avoidance actions, RICO, and omnibus alter ego proceedings (.3); correspond with Ancillary Legal regarding

Subtotal: B191 General Litigation 27.10 35,016.50

08/28/2024 NAB Travel to and from New York for Rule 4.00 917.50 3,670.00

2004 deposition and PH meeting regarding case developments and strategy (bill at 1/2 rate) Subtotal: B195 Non-Working Travel 4.00 3,670.00

Date Initials Description Hours Rate Amount

08/01/2024 DM26 Research certain targets and their corporate and service information 0.80 565.00 452.00 08/01/2024 DEB4 Participate in financial investigation update call with Kroll, N. Bassett, and L. Song 1.00 1,395.00 1,395.00 08/01/2024 ECS1 Correspond with law firms connected to

firm documents to the Trustee 0.20 1,270.00 254.00 08/01/2024 ECS1 Analyze information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.40 1,270.00 508.00 08/01/2024 ECS1 Review production documents in

2004 deposition (.7); prepare timeline, topic list for same (.1) 0.80 1,270.00 1,016.00 08/01/2024 IC Research regarding ACASS USA 0.30 420.00 126.00 08/01/2024 KL12 Research Hong Kong company records for two companies for L. Song 1.50 420.00 630.00 08/01/2024 LS26 Correspond with N. Bassett regarding review of criminal trial exhibits (0.2); continue to review criminal trial documents and exhibits in support of Trustee claims

08/01/2024 LS26 Meeting with N. Bassett, D. Barron, K. Mitchell (NPM), P. Linsey (NPM) and Kroll regarding investigation update (1.0); analyze facts re potential alter ego targets (0.6); correspond with A. Lomas (Kroll) regarding vehicle investigation (0.2); correspond with

08/01/2024 NAB Call with D. Barron, L. Song, P. Linsey

documents relating to same (.2); correspond with L. Song regarding next steps in device

08/02/2024 DEB4 Correspond with L. Song regarding Swiss related documents (0.4); analyze same (0.8) 1.20 1,395.00 1,674.00

who represented Debtor alter egos (.1); correspond with P. Linsey (NPM) regarding

08/02/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,270.00 254.00 08/02/2024 ECS1 Review production documents in

timeline, topic list and key documents in connection with same (.1); correspond with L. Song regarding same (.1) 0.30 1,270.00 381.00 08/02/2024 LS26 Analyze corporate records regarding potential alter ego targets (3.0); correspond

investigation of potential assets (0.4); review documents regarding same (0.2) 3.80 985.00 3,743.00 08/02/2024 NAB Correspond with Kroll regarding investigation findings 0.20 1,835.00 367.00 08/03/2024 NAB Review Kroll investigation findings (.2);

08/04/2024 DEB4 Analyze documents related to potential new alter egos (6.2); call with L. Song regarding

08/04/2024 ECS1 Review information regarding Kwok, his affiliates and assets, and their connections

08/04/2024 LS26 Analyze facts regarding potential alter ego targets (2.3); call with D. Barron regarding

regarding same (0.5); call and correspond

superseding indictment (0.1) 3.10 985.00 3,053.50 08/05/2024 AC40 Analyze Hong Kong law to determine course of action regarding the assets of a 2.00 985.00 1,970.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 147 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

Date Initials Description Hours Rate Amount

08/05/2024 DM26 Review certain media presentations received from local counsel and correspond with D.

08/05/2024 DEB4 Correspond with A. Bongartz regarding

08/05/2024 DEB4 Correspond with A. Chan regarding Hong

with A. Thorp regarding same (0.1); review

regarding alter ego jurisdictions and related information (0.4); correspond with A. Thorp regarding BVI discovery (0.1);

08/05/2024 LS26 Correspond with A. Lomas (Kroll) re bank statements (0.1); correspond with D. Barron re potential alter ego target analysis (0.4); analyze facts regarding potential alter ego targets (4.1); review external information sources re same (0.2) 4.80 985.00 4,728.00 08/05/2024 LS26 Review Debtor criminal trial exhibits in connection with Trustee claims 2.90 985.00 2,856.50 08/05/2024 NAB Correspond with L. Song regarding

08/06/2024 JPK1 Correspond with J. Bach regarding Rule 2004 deposition of M. Francis (.1);

08/06/2024 LS26 Continue to analyze criminal trial exhibits in connection with Trustee claims 1.50 985.00 1,477.50 08/06/2024 LS26 Continue to analyze documents related to potential alter ego targets (0.6); draft email

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 148 of 879

Date Initials Description Hours Rate Amount

08/06/2024 NAB Correspond with J. Kosciewicz regarding rule 2004 depositions and discovery issues

connection with same (.1) 0.30 1,835.00 550.50 08/07/2024 DEB4 Correspond with A. Thorp regarding BVI discovery (0.1); correspond with N. Bassett regarding criminal trial exhibits (0.1);

and alter ego analysis (0.3); analyze same

Hong Kong corporate documents (0.2); correspond with P. Linsey (NPM) regarding Cyprus documents (0.1) 1.30 1,395.00 1,813.50 08/07/2024 LS26 Call with D. Barron regarding alter ego analysis (0.3); correspond with D. Barron regarding same (0.6); continue to analyze facts regarding potential alter ego targets

regarding bank discovery (0.2); draft email

08/07/2024 LS26 Continue to review criminal trial exhibits in connection with Trustee claims (1.4);

08/01/2024 NAB Correspond with L. Song regarding Rule 2004 deposition preparations 0.20 1,835.00 367.00 08/08/2024 AB21 Correspond with D. Barron regarding tolling stipulation 0.10 1,850.00 185.00 08/08/2024 DEB4 Participate in financial investigation update call with Kroll 0.80 1,395.00 1,116.00 08/08/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.30 1,270.00 381.00 08/08/2024 ECS1 Correspond with N. Bassett and

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 149 of 879

Date Initials Description Hours Rate Amount

08/08/2024 ECS1 Review and follow up correspondence with

update tracker regarding same (.2);

08/08/2024 ECS1 Review email from J. Moran (Moritt Hock) re Raiche Ende Malter production (.1);

08/08/2024 LS26 Continue to review criminal trial exhibits in connection with Trustee claims 1.40 985.00 1,379.00 08/08/2024 LS26 Continue to analyze documents on potential omnibus alter ego targets 2.30 985.00 2,265.50 08/08/2024 NAB Correspond with L. Song regarding device

discovery relating to him (.4); follow up

(.4); correspond with N.

08/09/2024 FC21 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.30 1,270.00 381.00 08/09/2024 FCS1 Review and follow up correspondence with

update tracker regarding same (.2);

08/10/2024 LS26 Correspond with D. Barron re potential alter ego targets (0.3); review documents 0.60 985.00 591.00

Date Initials Description Hours Rate Amount

08/12/2024 DM26 Research certain corporate documents regarding HGA entities for L. Song 0.30 565.00 169.50 08/12/2024 ECS1 Correspond with P. Linsey (NPM) regarding 16th omnibus rule 2004 motion 0.20 1,270.00 254.00 08/12/2024 ECS1 Review and follow up correspondence with

the Trustee (.4); correspond with D. Barron regarding same (.3) 0.70 1,270.00 889.00 08/12/2024 ECS1 Correspond with UnitedLex regarding re designated Raich Ende Malter production 0.20 1,270.00 254.00 08/12/2024 ECS1 Review Dontzin production of Ace Decade

08/12/2024 LS26 Continue to review documents regarding alter ego targets (0.4); correspond with K.

regarding rule 2004 discovery (0.1); correspond with K. Mitchell and D. Barron regarding involvement of certain law firms (0.1); correspond with N. Bassett and D.

08/12/2024 NAB Correspond with L. Song regarding discovery issues (.1); review draft Rule 2004 motion and email with P. Linsey regarding

08/13/2024 DEB4 Correspond with L. Song regarding Kwok criminal trial exhibits and pleadings (0.2);

(0.3); analyze same (1.2); correspond with L. Despins regarding Mother Jones article (0.2) 1.90 1,395.00 2,650.50 08/13/2024 ECS1 Review and prepare summary of Raich

UnitedLex, P. Parizek (Kroll), and P. Linsey

08/13/2024 ECS1 Review and follow up correspondence with

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 151 of 879

Date Initials Description Hours Rate Amount

08/13/2024 LS26 Call with D. Barron regarding potential alter ego entities and criminal case proceedings (0.3); correspond with D. Barron regarding

(0.3); review public information relating to Debtor and his associates (0.5) 1.30 985.00 1,280.50 08/14/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,270.00 254.00 08/14/2024 ECS1 Review and follow up correspondence with

08/14/2024 LS26 Draft email to A. Thorp (Harneys Legal) regarding certain BVI entities (0.2); review

08/15/2024 DEB4 Correspond with P. Linsey (NPM) regarding Headwater vehicles 0.20 1,395.00 279.00

08/15/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,270.00 254.00 08/15/2024 ECS1 Review and follow up correspondence with

the Trustee (.3); update tracker summarizing

08/15/2024 KL12 Research annual returns of 11 Hong Kong companies for L. Song 0.80 420.00 336.00 08/15/2024 LS26 Review informant correspondence and 11 - - - C - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 2.00 985.00 1,970.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 152 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

Date Initials Description Hours Rate Amount

08/16/2024 LS26 Continue to review public information about the Debtor (2.2); draft email to L.

regarding same (0.5) 2.70 985.00 2,659.50 08/18/2024 LS26 Prepare outline for Ross Heinemeyer Rule

08/19/2024 DEB4 Correspond with E. Sutton regarding documents from law firms (0.3); correspond

services (0.1); correspond with P. Linsey regarding conflicted parties (0.1) 0.50 1,395.00 697.50 08/19/2024 ECS1 Review issues and notes in preparation for call with Chris Major (Meister) regarding production of Meister's documents (.1);

08/19/2024 ECS1 Review and follow up correspondence with

the Trustee (.3); correspond with D. Barron regarding same (.1) 0.40 1,270.00 508.00 08/19/2024 IC Research regarding Q. Ju 0.20 420.00 84.00 08/19/2024 JPK1 Correspond with J. Bach regarding M. Francis Rule 2004 subpoena 0.10 1,185.00 118.50 08/19/2024 LS26 Continue to prepare outline for Ross Heinemeyer rule 2004 deposition 7.50 985.00 7,387.50 08/19/2024 NAB Correspond with L. Song regarding deposition preparations 0.10 1,835.00 183.50 08/20/2024 DEB4 Conference with L. Song regarding investigation documents (0.4); correspond

deposition (0.4); correspond with L.

accounts (0.1); correspond with N. Bassett regarding documents from law firms (0.2);

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 153 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

the Trustee (.2); conference with D. Barron regarding same (.1); correspond with D. Barron and L. Song regarding same (.1) Hours

08/20/2024 ECS1 Correspond with D. Barron and N. Bassett regarding Chris Major (Meister) production of Meister's documents 0.30 1,270.00 381.00 08/20/2024 JPK1 Correspond with counsel for M. Francis regarding Rule 2004 deposition (.2);

08/20/2024 LS26 Call and correspond with P. Linsey (NPM) re Lexus vehicle found in Taconic home 0.30 985.00 295.50 08/20/2024 LS26 Review documents produced by law firms retained by debtor alter ego entities (0.4);

(0.1); correspond with D. Barron and E. Sutton regarding same (0.2) 0.70 985.00 689.50 08/20/2024 LS26 Continue to draft Ross Heinemeyer rule 2004 deposition outline 4.70 985.00 4,629.50 08/20/2024 LS26 Review documents regarding P. Patel (0.3);

and additional investigation documents (0.4) 0.70 985.00 689.50 08/20/2024 NAB Correspond with L. Song regarding Rule

same (.3); correspond with L. Despins and

analysis of same (.3); review revised A. Mitchell privilege log (.2); correspond with J. Kosciewicz regarding same (.1) 1.00 1,835.00 1,835.00 08/21/2024 DEB4 Correspond with N. Bassett and L. Despins regarding law firm documents (0.3);

08/21/2024 DEB4 Correspond with P. Linsey (NPM)

(0.1); correspond with L. Song regarding informant (0.1) 0.20 1,395.00 279.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 154 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

Date Initials Description Hours Rate Amount 08/21/2024 ECS1 Correspond with D. Barron regarding call with Chris Major (Meister) regarding production of Meister's documents 0.10 1,270.00 127.00 08/21/2024 JPK1 Attend meet and confer with J. Bach, counsel for M. Francis, and N. Bassett regarding Rule 2004 deposition (.3); correspond with L. Song regarding the same (.2); correspond with N. Bassett regarding the same (.1) 0.60 1,185.00 711.00 08/21/2024 LS26 Analyze payments to M. Francis (0.6); analyze documents relating to the vehicle (0.6); review public information relating to the Debtor and Debtor-related entities (0.3) 1.50 985.00 1,477.50 08/21/2024 NAB Correspond with D. Barron and L. Despins regarding discovery issues (.2); correspond with L. Song regarding same (.2); call with counsel to M. Francis and J. Kosciewicz regarding Rule 2004 deposition issues (.3); prepare notes for same (.1); correspond with E. Sutton regarding same (.2); review outline and related documents in preparation for Rule 2004 depositions (.5) 1.50 1,835.00 2,752.50 08/22/2024 DEB4 Correspond with J. Barker regarding headwater services (0.2); review issues regarding same (0.1); participate in financial analysis update call with Kroll, L. Despins, N. Bassett, and L. Song (0.7) 1.00 1,395.00 1,395.00 08/22/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.30 1,270.00 381.00 08/22/2024 ECS1 Call with Chris Major (Meister) regarding production of Meister's documents (.2); prepare notes regarding same (.1) 0.30 1,270.00 381.00 08/22/2024 ECS1 Review and follow up correspondence with law firms connected to Debtor alter egos regarding turnover of firm documents to the Trustee (.2); correspond with D. Barron 0.30 1,270.00 381.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 155 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

Date Initials Description Hours Rate Amount

08/22/2024 JPK1 Analyze A. Mitchell privilege log regarding entries for which Genever Holdings is listed as a common interest party (.3); correspond with N. Bassett regarding the same (.2); correspond with A. Mitchell regarding the

08/22/2024 LAD4 Handle Kroll weekly call with D. Barron, N. Bassett, L. Song 0.70 1,975.00 1,382.50 08/22/2024 LS26 Conference with L. Despins, N. Bassett, D.

about the Debtor (0.3) 1.00 985.00 985.00 08/22/2024 NAB Review and revise draft Rule 2004 deposition outline (1.4); review exhibits in connection with same (.7); correspond with L. Despins and L. Song regarding same (.1); participate in call with L. Despins, D. Barron, P. Linsey (NPM), L. Song and Kroll regarding case/financial analyses updates and strategy (.7); review discovery issues related to device data extraction (.2);

privilege log issues (.1) 3.20 1,835.00 5,872.00 08/23/2024 DEB4 Conferences with E. Sutton regarding documents from law firms (0.3); conference

regarding same (0.1) 0.80 1,395.00 1,116.00 08/23/2024 ECS1 Review and follow up correspondence with

the Trustee (.1); conference with D. Barron regarding same (.2); call with J. Swergold (Yankwitt) and D. Barron regarding Victor Cerda's production of alter ego documents

connection with same (.4); follow up call with D. Barron regarding same (.1) 1.20 1,270.00 1,524.00

Date Initials Description Hours Rate Amount

08/23/2024 NAB Correspond with L. Song regarding deposition and discovery issues 0.20 1,835.00 367.00 08/24/2024 NAB Review and comment on outline for Rule 2004 depositions (0.9); correspond with L.

08/25/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,270.00 254.00 08/25/2024 LS26 Review and revise Ross Heinemeyer deposition outline (0.7); review exhibits for

08/25/2024 NAB Review and revise rule 2004 deposition outline (1.3); review exhibits and documents in connection with the same (0.5); correspond with L. Song regarding the same

08/26/2024 DEB4 Correspond with W. Farmer regarding 0.10 1,395.00 139.50 08/26/2024 ECS1 Review and follow up correspondence with

the Trustee (.2); update tracker summarizing

08/26/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corproate information 0.60 1,270.00 762.00 08/26/2024 LS26 Call with N. Bassett re Ross Heinemeyer deposition (0.3); correspond with N. Bassett

08/26/2024 NAB Review documents and supplement outline for Rule 2004 depositions (0.6); telephone 0.90 1,835.00 1,651.50

conference with L. Song regarding the same

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 157 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

Correspond with L. Song regarding William Je documents (0.1); correspond with E. Sutton regarding documents form law firms

08/27/2024 ECS1 Review and comment on new production

regarding same (.1) 0.80 1,270.00 1,016.00 08/27/2024 ECS1 Review and follow up correspondence with

the Trustee (.2); update tracker summarizing

08/27/2024 ECS1 Review email from N. Bassett to

08/27/2024 ECS1 Review information regarding Kwok, his affiliates and assets, and their connections

08/27/2024 ECS1 Call with M. Levine (Elliott Kwok Levine Jaraslow) regarding turnover of alter ego

notes in preparation for same (.1);

08/27/2024 ECS1 Correspond with L. Song re deposition of

connection with same 0.30 1,270.00 381.00 08/27/2024 LS26 Review K Legacy disclosure documents (0.3); review documents and legal issues in

2004 deposition (6.3); call with N. Bassett regarding same (0.5); review and revise R. Heinemeyer deposition outline (1.4) 8.50 985.00 8,372.50 08/27/2024 NAB Telephone conference with L. Song

outline and documents relating to the same

Date Initials Description Hours Rate Amount

08/28/2024 DEB4 Conference with N. Bassett and L. Song

08/28/2024 LAD4 T/c N. Bassett, L. Song re: discovery & rule

08/28/2024 LS26 Correspond with D. Barron re Hamilton

regarding same (0.4); call with P. Linsey re investigation update (0.2) 0.90 985.00 886.50 08/28/2024 LS26 Meeting with N. Bassett in prep for rule 2004 deposition (0.6); conduct R. Heinemeyer rule 2004 deposition (3.6); review documents, legal issues, and outline in preparation for deposition (2.6); conference with L. Despins, N. Bassett, re R. Heinemeyer deposition (0.2); conference

08/28/2024 NAB Meet with L. Song regarding preparation for Rule 2004 deposition (0.6); participate in the same (3.6); conference with L. Despins and L. Song regarding the same (0.2);

regarding discovery issues (0.3) 4.70 1,835.00 8,624.50 08/29/2024 DEB4 Conference with L. Song regarding

informant interview (0.2); correspond with L. Song regarding same (0.2) 0.40 1,395.00 558.00 08/29/2024 DEB4 Correspond with L. Song regarding BVI

08/29/2024 ECS1 Review and follow up correspondence with

the Trustee (.1); update tracker summarizing

08/29/2024 ECS1 Review email from N. Bassett to

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 159 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

Date Initials Description Hours Rate Amount

08/29/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information (.1);

parties in interest (.1); correspond with L. Despins and P. Linsey (NPM) re same (.1) 0.30 1,270.00 381.00 08/29/2024 JPK1 Correspond with A. Mitchell regarding

from privilege log 0.20 1,185.00 237.00 08/29/2024 LS26 Review documents relating to potential

08/29/2024 LS26 Review and revise potential interview topics (1.0); conference with D. Barron regarding same (0.2); draft email to N. Bassett and D. Barron regarding additional documents for asset investigation (0.3); correspond with potential informant regarding meeting (0.4) 1.90 985.00 1,871.50 08/29/2024 NAB Correspond with L. Song regarding

connection with same (.7); correspond with regarding same (.3) 1.60 1,835.00 2,936.00 08/30/2024 DEB4 Correspond with L. Despins and P. Linsey

prepetition litigation documents (0.3); correspond with P. Linsey regarding Rui Ma prepetition litigation (0.1) 0.40 1,395.00 558.00 08/30/2024 ECS1 Review and follow up correspondence with

08/30/2024 LS26 Review documents regarding potential

08/31/2024 DEB4 Review and consider correspondence from L. Song regarding Mileson 0.50 1,395.00 697.50 Subtotal: B261 Investigations 154.20 182,197.50 Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 160 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2429377

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 0.90 1,975.00 1,777.50 NAB Nicholas A. Bassett Partner 22.20 1,835.00 40,737.00 NAB Nicholas A. Bassett Partner 4.00 917.50 3,670.00 AB21 Alex Bongartz Of Counsel 1.70 1,850.00 3,145.00 DEB4 Douglass E. Barron Associate 27.40 1,395.00 38,223.00 ECS1 Ezra C. Sutton Associate 30.00 1,270.00 38,100.00 JPK1 Jon P. Kosciewicz Associate 2.00 1,185.00 2,370.00 KC27 Kristin Catalano Associate 2.40 1,185.00 2,844.00 AC40 Alex Chan Associate 2.00 985.00 1,970.00 LS26 Luyi Song Associate 85.90 985.00 84,611.50 DM26 David Mohamed Paralegal 4.00 565.00 2,260.00

Date Description Quantity Rate Amount 08/20/2024 Photocopy Charges 120.00 0.08 9.60

Photocopy Charges (Color) 290.00 0.20 58.00

Photocopy Charges (Color) 2,400.00 0.20 480.00

Outside Professional Services DSAI April 25,889.21

05/31/2024 UnitedLex Invoices - Unitedlex Corp, Invoice# 098546 Dated 05/31/24, UnitedLex – DSAI May 2024 Charges – Outside Professional Services 19,411.91

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 23

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 99 dated 07/28/2024; Douglass Barron; Dinner; Restaurant: Thai V Express; Number of People: 1;

(USD)(JPMPCARD); Invoice # 857236192; 07/23/2024; Sharon Jones Santiago Rodrique; East West Bank; 135 N LOS ROBLES AVE; PASADENA, CA 91101 ; 277416976223 (MAN) 20.34

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 99 dated 07/28/2024; Douglass Barron; Dinner; Restaurant: Evergreen on 38; Number of People 1;

David Mohamed; 07/25/2024; Purchase of Status report from DE-SOS for \$20; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000, Statement Date:

David Mohamed; 07/26/2024; Purchase of corporate documents from United Corporate Services for \$222.11; Merchant: United Corp Services Location: 914-949-9188, NY 10606- 0000, Statement Date: 07/31/2024, Post Date:

104001665 Dated 08/01/24, Services between June

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 24

08/01/2024 Computer Search (Other) 1.44

(USD)(JPMPCARD); Invoice # 858749722; 08/06/2024; Kevin Lynn; 211 Rod Cir;

08/06/2024 Computer Search (Other) 3.51

Shlomo Maza; 07/31/2024; Restaurant: Crazy Meat; City: Jamaica; Dinner; Number of people: 1; Late Work Dinner 40.00

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 100 dated 08/11/2024; Douglass Barron; Dinner;

People: 1; Location: New York; Kwok; Order #

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 100 dated 08/11/2024; Douglass Barron; Dinner; Restaurant: Evergreen on 38; Number of People: 1;

08/10/2024 Computer Search (Other) 1.26

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 101 dated 08/25/2024; Douglass Barron; Restaurant: Noodle Shop; Number of People: 1; Dinner; Location: New York; Kwok; Order #

08/13/2024 Computer Search (Other) 14.22

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 25

Ezra Sutton; 08/14/2024; Restaurant: Hummus Kitchen ; City: New York ; Dinner; Number of people: 1; Working late night 17.21

Ezra Sutton; 08/14/2024; From/To: Office/Home ; Service Type: Uber; Time: 21:45;

(USD)(JPMPCARD); Invoice # 860803072; 08/26/2024; MEI GUO; 492 BROOM STREET; NEW YORK, NY 10013; 278735545999 (MAN) 84.34

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 102 dated 09/08/2024; Douglass Barron; Restaurant: Evergreen on 38; Lunch; Number of People: 1; Location: New York; Kwok; Order #

08/26/2024 Computer Search (Other) 7.74

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 164 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 26

Managing or General Immobiliare Barbara 2000

304-78941 Dated 08/27/24, Recipient -Maurizio Azzi Immobiliare Barbara 2000 SIRL Via Bologna,

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 102 dated 09/08/2024; Douglass Barron; Restaurant: Evergreen on 38; Number of People: 1; Dinner; Location: New York; Kwok; Order #

Luc Despins; 08/21/2024; From/To: Office/Meeting ; Service Type: Uber; Time: 09:34;

20240829PT Dated 08/29/24, company search fee on 15 August 2024; requested by D. Barron 2.05

20240829PT Dated 08/29/24, company search fee on 15 August 2024 for 10 companies; requested by

20240829PT Dated 08/29/24, company search fee on 1 August 2024; requested by L. Song 203.97

08/30/2024 Electronic Document Retrieval - David Mohamed; 08/12/2024; Purchase of Corporate Documents from NJ-Dept. of Treasury, Div of Revenue for \$0.30; Merchant: NJ business services 0.30

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 165 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 27

Total Costs incurred and advanced \$99,321.78

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 102 dated 09/08/2024; Douglass Barron; Restaurant: Aki Chinese; Number of People: 1;

David Mohamed; 08/01/2024; Purchase of status report & cert of formation from NJ-Dept. of Treasury, Div of Revenue for \$6.35 – Headwater Service LLC; Merchant: NJ Business Services Location: Egov.Com, NJ 08608-0000, Statement Date: 08/30/2024, Post Date:

David Mohamed; 08/01/2024; Purchase of Status report from DE-SOS for \$10 – ACASS U.S.A. Inc.; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000, Statement Date: 08/30/2024, Post Date:

08/30/2024 Electronic Document Retrieval - David Mohamed; 08/19/2024; Purchase of status report from DE

08/30/2024 Electronic Document Retrieval - David Mohamed; 08/19/2024; Purchase of status report from DE

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 166 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Other Litigation PH LLP Client/Matter # 50687-00003 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$3,279.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 167 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Other Litigation PH LLP Client/Matter # 50687-00003 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$3,279.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 168 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho February 7, 2025

New York, NY 10166 Invoice Number: 2429378

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending August 31, 2024

Date Initials Description Hours Rate Amount

08/16/2024 NAB Review criminal case filings 0.10 1,835.00 183.50 08/17/2024 NAB Correspond with L. Despins regarding criminal case issues 0.20 1,835.00 367.00 08/21/2024 NAB Analyze criminal trial issues (.1); correspond with L. Despins regarding same (.1) 0.20 1,835.00 367.00 08/23/2024 SM29 Reply to email from L. Despins re criminal case issues (.2); review criminal case docket

08/26/2024 NAB Correspond with L. Despins regarding criminal case issues 0.10 1,835.00 183.50 08/27/2024 LAD4 T/c N. Bassett re: government and criminal

08/27/2024 NAB Telephone conference with L. Despins

08/29/2024 LS26 Review Debtor's criminal case docket

criminal case filings (0.1) 0.30 985.00 295.50 Subtotal: B191 General Litigation 1.90 3,279.50 Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 169 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2429378

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 0.30 1,975.00 592.50 NAB Nicholas A. Bassett Partner 0.90 1,835.00 1,651.50 SM29 Shlomo Maza Of Counsel 0.40 1,850.00 740.00 LS26 Luyi Song Associate 0.30 985.00 295.50

Date Description Quantity Rate Amount

Total Costs incurred and advanced \$4.05

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 170 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Sales Process PH LLP Client/Matter # 50687-00005 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$9,720.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 171 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Sales Process PH LLP Client/Matter # 50687-00005 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$9,720.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 172 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho February 7, 2025

New York, NY 10166 Invoice Number: 2429379

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending August 31, 2024

Date Initials Description Hours Rate Amount

08/02/2024 ECS1 Analyze issues regarding purchase of

08/20/2024 ECS1 Call with W. Sherman (NPM) and L.

property and real estate broker retention (.2); correspond with L. Despins and W. Sherman (NPM) regarding same (.2) 0.40 1,270.00 508.00 08/20/2024 LAD4 Meeting with broker at 373 Taconic re:

(.20); t/c W. Sherman and E. Sutton re:

08/22/2024 LAD4 Continue to review/comment on transition/sale issues 2.10 1,975.00 4,147.50 Subtotal: B131 Sale of Real Estate 5.10 9,720.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 173 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 2

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 4.60 1,975.00 9,085.00 ECS1 Ezra C. Sutton Associate 0.50 1,270.00 635.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 174 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Tax Issues PH LLP Client/Matter # 50687-00006 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$4,589.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 175 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Tax Issues PH LLP Client/Matter # 50687-00006 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$4,589.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 176 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho February 7, 2025

New York, NY 10166 Invoice Number: 2429380

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending August 31, 2024

Date Initials Description Hours Rate Amount

08/07/2024 AB21 Prepare insert for tax return (0.9); call with E. Sutton regarding additional background documents (0.1) 1.00 1,850.00 1,850.00 08/07/2024 ECS1 Review records related to Lady May purchase price and escrowed funds (.5); call with A. Bongartz regarding same (.1); correspond with A. Bongartz re same (.1) 0.70 1,270.00 889.00 08/08/2024 AB21 Revise insert for tax return (0.2);

regarding same (0.2) 0.40 1,850.00 740.00 08/09/2024 AB21 Correspond with A. Calascibetta (EA Group) regarding tax returns 0.10 1,850.00 185.00 08/22/2024 AB21 Call with J. Lindenberg (EA Group) regarding preparation of tax returns 0.50 1,850.00 925.00 Subtotal: B240 Tax Issues 2.70 4,589.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 177 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00006 Invoice No. 2429380 Timekeeper Summary ID Timekeeper Name Title Hours Rate Fee AB21 Alex Bongartz Of Counsel 2.00 1,850.00 3,700.00 ECS1 Ezra C. Sutton Associate 0.70 1,270.00 889.00 Current Fees and Costs \$4,589.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 178 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Foreign Law Issues PH LLP Client/Matter # 50687-00007 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$420.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 179 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Foreign Law Issues PH LLP Client/Matter # 50687-00007 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$420.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 180 of 879

t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Attn: Luc Despins New York, NY 10166 Luc Despins as Chapter 11 Trustee in the case of Ho February 7, 2025 Please Refer to Invoice Number: 2429381 PH LLP Tax ID No. 95-2209675 for the period ending August 31, 2024 FOR PROFESSIONAL SERVICES RENDERED

Date Initials Description Hours Rate Amount

08/28/2024 CT16 Research regarding UK service information 1.00 420.00 420.00 Subtotal: for E. Sutton B191 General Litigation 1.00 420.00

Total Balance Due - Due Upon Receipt \$420.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 181 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever US PH LLP Client/Matter # 50687-00010 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$15,110.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 182 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever US PH LLP Client/Matter # 50687-00010 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$15,110.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 183 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho February 7, 2025

New York, NY 10166 Invoice Number: 2429382

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending August 31, 2024

Date Initials Description Hours Rate Amount

08/07/2024 AB21 Correspond with S. Boardman (Sothebys)

08/21/2024 LAD4 Visit SN apartment and discussion with broker re: next steps 1.70 1,975.00 3,357.50 08/22/2024 LAD4 T/c Judge Cyganowski (sale officer) re: sale price of apartment (.30); emails to Serana Boardman (Sothebys) re: same (.20) 0.50 1,975.00 987.50 08/28/2024 AB21 Correspond with L. Despins regarding sale

08/29/2024 AB21 Correspond with S. Millman (Hogan Lovells) regarding sale stipulations 0.10 1,850.00 185.00 Subtotal: B131 Sale of Real Estate 2.60 5,085.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 184 of 879

Date Initials Description Hours Rate Amount

08/12/2024 AB21 Travel from office to SN apartment for

and Sciame (bill at 1/2 rate) 0.60 925.00 555.00 08/15/2024 AB21 Travel from office to SN apartment and back (bill at 1/2 rate) 0.60 925.00 555.00 Subtotal: B195 Non-Working Travel 1.20 1,110.00

08/06/2024 AB21 Calls with D. Acheson (architect) regarding completion of remediation project (0.2); correspond with L. Despins regarding same

08/07/2024 AB21 Call with S. Millman (Hogan Lovells)

process (0.4); correspond with L. Despins regarding same (0.2) 0.60 1,850.00 1,110.00 08/08/2024 AB21 Correspond with D. Acheson (architect) regarding outstanding invoices 0.10 1,850.00 185.00 08/12/2024 AB21 Meeting with B. Snyder (Acheson Doyle)

remediation projects (0.7); correspond with L. Despins regarding same (0.4) 1.10 1,850.00 2,035.00 08/13/2024 AB21 Revise notice of Acheson Doyle invoices

regarding filing and service of same (0.1) 0.20 1,850.00 370.00 08/13/2024 AB21 Correspond with T. Sadler regarding SN remediation-related invoice (0.1);

Netherland) regarding same (0.1) 0.20 1,850.00 370.00 08/14/2024 AB21 Call and correspond with D. Acheson (architect) regarding update on remediation projects (0.1); correspond with L. Despins regarding same (0.1) 0.20 1,850.00 370.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 185 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2429382

Date Initials Description Hours Rate Amount

08/15/2024 AB21 Meeting with D. Acheson (architect)

(0.3); correspond with L. Despins regarding

08/22/2024 LAD4 claim T/c J. Panico (AAGL) re: size of insurance 0.50 1,975.00 987.50

outstanding DIP balance (0.1); correspond with T. Sadler regarding same (0.1) 0.20 1,850.00 370.00

Subtotal:

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 2.70 1,975.00 5,332.50 AB21 Alex Bongartz Of Counsel 3.80 1,850.00 7,030.00 AB21 Alex Bongartz Of Counsel 1.20 925.00 1,110.00 TS21 Tess Sadler Associate 1.20 1,365.00 1,638.00

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 186 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever BVI PH LLP Client/Matter # 50687-00011 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$7,385.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 187 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever BVI PH LLP Client/Matter # 50687-00011 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$7,385.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 188 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho February 7, 2025

New York, NY 10166 Invoice Number: 2429383

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending August 31, 2024

Date Initials Description Hours Rate Amount

08/13/2024 AB21 Analyze company filing regarding lien releases (1.3); call with L. Song regarding

08/13/2024 LS26 Review documents relating to Alzarro loan arrangement (0.8); call with A. Bongartz re

08/15/2024 AB21 Analyze issues related to release of charge against Genever BVI (1.0); correspond with L. Despins regarding same (0.1); correspond

08/20/2024 AB21 Correspond with G. Weston (Harneys Legal) regarding lien release 0.10 1,850.00 185.00 Subtotal: B231 Security Document Analysis 4.60 7,385.50

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 189 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00011 Invoice No. 2429383

ID Timekeeper Name Title Hours Rate Fee

AB21 Alex Bongartz Of Counsel 3.30 1,850.00 6,105.00 LS26 Luyi Song Associate 1.30 985.00 1,280.50

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 190 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00012 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$208,702.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 191 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00012 Luc A. Despins

Legal fees for professional services for the period ending August 31, 2024 \$208,702.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 192 of 879

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending August 31, 2024

Date Initials Description Hours Rate Amount

08/05/2024 LAD4 Review/edit request for Mahwah hearing 0.40 1,975.00 790.00 08/06/2024 LAD4 Review cost issues & prepare notes for

08/08/2024 DEB4 Correspond with N. Bassett regarding status

08/13/2024 NAB Review issues and prepare notes for status

hearing on motion to authorize payment of expenditures (.5) 0.80 1,835.00 1,468.00 Subtotal: B155 Court Hearings 2.20 4,175.00

08/01/2024 DM26 Review and file via the Court's CM/ECF

Case 22-50073 Doc 4157 Filed 02/24/25 Entered 02/24/25 19:13:24 Page 193 of 879

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2429384

Date Initials Description Hours Rate Amount

08/01/2024 DEB4 Correspond with N. Bassett and L. Despins regarding Taurus authority issues 0.30 1,395.00 418.50 08/01/2024 LS26 Prepare notice of stay termination (1.0);

filing (0.3); correspond with N. Bassett, L. Despins, D. Barron and P. Linsey (NPM) re same (0.1); call and correspond with P. Linsey re same (0.2) 1.70 985.00 1,674.50 08/02/2024 NAB Analyze litigation next steps and summary

08/02/2024 WCF Draft stipulation to stay New Jersey state court mechanics' lien lawsuit against Taurus

Roofing) (1.2); correspond with N. Bassett regarding revisions to same (.1) 1.30 1,390.00 1,807.00 08/04/2024 NAB Analyze next steps in adversary proceeding and reply to defendants' response to court

and P. Linsey (NPM) regarding same (.6);

connection with same (.3) 1.20 1,835.00 2,202.00 08/05/2024 DEB4 Correspond with P. Linsey (NPM) regarding Mahwah emergency motion (0.1);

summary judgment (0.3) 0.40 1,395.00 558.00 08/05/2024 LS26 Call and correspond with P. Linsey (NPM) regarding trustee's objection to defendant's

08/05/2024 NAB Review and revise draft reply to response to Court order requiring filing of notice and certain disclosures by defendant (.7);

(NPM) regarding same (.3); further analyze and outline litigation strategy and next steps for adversary proceeding (.5) 1.50 1,835.00 2,752.50

Date Initials Description Hours Rate Amount

08/05/2024 SM29 Call with D. Barron re summary judgment

08/05/2024 WCF Revise stipulation regarding Fania Roofing state court mechanics' lien action (.4);

(opposing counsel) regarding same (.1);

08/06/2024 DEB4 Correspond with N. Bassett regarding Mahwah motion for summary judgment 0.10 1,395.00 139.50 08/06/2024 NAB Email with P. Linsey (NPM) and W. Farmer

deadlines (.3); analyze issues related to same

08/06/2024 WCF Review prior document productions and

outstanding requests before criminal stay (.6); correspond with vendor, UnitedLex, P.

08/07/2024 LAD4 Review/edit motion to approve payment of expense (.80); emails to P. Linsey (NPM) re: same (.30); t/c P. Linsey re: same (.20) 1.30 1,975.00 2,567.50 08/07/2024 NAB Email with M. Conway (defense counsel) regarding proposed schedule for litigation (.2); analyze authority regarding summary judgment strategy (.7); email with W. Farmer regarding litigation issues relating to

08/08/2024 LS26 Prepare request for status conference re

08/08/2024 NAB Prepare parts of summary judgment motion

counsel) regarding litigation schedule (.2); email with L. Song regarding same (.2); review and revise draft request for status 1.40 1,835.00 2,569.00

Date Initials Description Hours Rate Amount

08/09/2024 DEB4 Correspond with N. Bassett regarding motion for summary judgment 0.20 1,395.00 279.00 08/09/2024 DEB4 Correspond with N. Bassett regarding

(0.2); analyze same (0.6) 0.80 1,395.00 1,116.00 08/09/2024 LS26 Review Taurus motion to withdraw the

08/09/2024 NAB Review motion to withdraw the reference

judgment issues and related authority (.4) 1.00 1,835.00 1,835.00 08/11/2024 NAB Further analyze motion to withdraw the reference and related adversary proceeding scheduling issues 0.50 1,835.00 917.50 08/12/2024 LS26 Review criminal trial exhibits relating to Mahwah Mansion (0.3); correspond with D. Barron regarding same (0.1) 0.40 985.00 394.00 08/12/2024 NAB Analyze motion to withdraw reference (.3);

same (.2); review defendants' response to

expenditures (.3) 0.80 1,835.00 1,468.00 08/13/2024 LS26 Analyze facts for summary judgment

08/14/2024 DEB4 Correspond with L. Despins and N. Bassett regarding Conway email 0.20 1,395.00 279.00 08/19/2024 DEB4 Conference and correspond with L. Song

motion (0.4); analyze documents related to

08/19/2024 LS26 Call and correspond with D. Barron

Mansion (0.1); analyze facts in connection 0.90 985.00 886.50

Date Initials Description Hours Rate Amount

08/20/2024 DEB4 Analyze documents related to Mahwah summary judgment motion 1.20 1,395.00 1,674.00 08/20/2024 DEB4 Correspond with N. Bassett regarding Mahwah evidentiary issues (0.2); correspond with L. Song regarding same (0.1) 0.30 1,395.00 418.50 08/20/2024 NAB Correspond with D. Barron regarding

litigation strategy (.2) 0.50 1,835.00 917.50 08/21/2024 DEB4 Conference with P. Linsey (NPM) regarding

(0.1); conference with N. Bassett and M. Conway regarding next steps (0.5); follow up call with N. Bassett regarding same and summary judgment motion (0.2); conference with N. Bassett and L. Despins

08/21/2024 LAD4 T/c D. Barron and N. Bassett re: summary

08/21/2024 LS26 Analyze facts and documents in connection with summary judgment motion 4.80 985.00 4,728.00 08/21/2024 NAB Call with D. Barron and M. Conway

resolution of litigation (.5); follow-up call