Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #4159

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., : :

Debtors1 :

**COVERSHEET RE: SEVENTH INTERIM APPLICATION OF NEUBERT, PEPE & MONTEITH, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES AS LOCAL AND CONFLICTS COUNSEL TO THE CHAPTER 11 TRUSTEE AND AS COUNSEL TO DEBTORS GENEVER HOLDINGS CORPORATION AND GENEVER HOLDINGS LLC**

Time Period: September 1, 2024 through December 31, 2024

Bankruptcy Petition Filed: February 15, 2022

Date of Entry of Ret'n Orders: (i) Aug. 2, 2022 [ECF No. 669] (Kwok), effective a/o July 8, 2022, (ii) Nov. 17, 2022 [ECF No. 1107] (Genever Holdings Corp.), effective a/o Oct. 11, 2022; and (iii) Nov. 30, 2022 [ECF No. 1177] (Genever Holdings LLC), effective a/o Nov. 3, 2022.

Fees: \$1,095,419.00 Voluntary Fee Reductions: \$20,000.00 Expenses: \$30,859.27 Fees After Vol. Reductions: \$1,075,419.00 Total Fees and Expenses after Copies page cost: \$0.15/page \$0.00 total Vol. Red.: \$1,106,278.27 Fees Previously Requested: Expense Detail:

Requested Fees: \$4,874,027.50 Retainer Received: \$0.00 Awarded Fees: \$4,833,844.50 Prior award applied: \$0.00

Paid Fees: \$4,453,649.40[2] Balance before this request: \$ 0.00

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

2 In addition, NPM has been paid: \$260,030.80 as 80% of its fees and 100% of its expenses for the month of September 2024 pursuant to its September 2024 Monthly Fee Statement. Hours and Rates per professional:

Kinsella 12/1991 Counsel 90.5 \$475.00 \$42,987.50 8 Douglas S. Skalka 10/1985 Partner 110 \$550.00 \$60,500.00 19 Dennis M. Carnelli 11/2013 Partner 166.00 \$480.00 \$79,680.00 20 Robert B. Flynn 08/1995 Partner 103.60 \$500.00 \$51,800 41 Patrick R. Linsey 11/2010 Partner 756.6 \$495.00 \$374,517.00 82 James C. Graham 11/1984 Partner 170.8 \$495.00 \$84,546.00 72 William C. Sherman 11/2010 Partner 183.4 \$480.00 \$88,032.00 68 Kari A. Mitchell 06/2016 Counsel 549.00 \$425.00 \$233,325.00

Jones N/A Paralegal 48.0 \$220.00 \$10,560.00 54 Sarah N. Smeriglio 10/2022 Associate 49.0 \$355.00 \$17,395.00 90 Michael J. O'Sullivan 10/2022 Associate 15.3 \$355.00 \$5,431.50 28 Lauren T. Astone 11/2021 Associate 16.5 \$355.00 \$5,857.50

Ahumada N/A Paralegal 120.4 \$200.00 \$24,080.00

Pierce N/A Paralegal 73.10 \$225.00 \$16,447.50 92 Lori A. Aiello N/A Paralegal 1.3 \$200.00 \$260.00

Total Hours: 2,453.5 Total Fees: \$1,095,419.00 (before \$20,000 voluntary reduction) Blended Hourly Rate: \$ 446.47 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, :

Debtor. :

**SEVENTH INTERIM APPLICATION OF NEUBERT, PEPE & MONTEITH, P.C., AS LOCAL AND CONFLICTS COUNSEL TO THE CHAPTER 11 TRUSTEE AND AS COUNSEL TO DEBTORS GENEVER HOLDINGS CORPORATION AND GENEVER HOLDINGS LLC FOR ALLOWANCE OF FEES AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM SEPTEMBER 1, 2024 THROUGH DECEMBER 31, 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"), and 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 [ECF No. 2094] (the "Interim Compensation Procedures Order"), Neubert, Pepe and Monteith, P.C. ("NPM" or "Applicant"), as local and conflicts counsel to Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok (the "Individual Debtor"), and as counsel to the Debtors, Genever Holdings Corporation ("Genever (BVI)") and Genever Holdings LLC ("Genever (US)") in their chapter 11 cases (together with the "Chapter 11 Case," collectively, the "Chapter 11 Cases"), hereby files this *Seventh Interim Application of Neubert, Pepe and Monteith, P.C., as Local and Conflicts Counsel to the Chapter 11 Trustee and as Counsel to Debtors Genever Holdings Corporation and Genever Holdings LLC, for Allowance of Fees and Reimbursement Expenses for* the Period from September 1, 2024 through December 31, 2024 (the "Application"). By this Application, NPM \requests interim allowance of professional fees and reimbursement of expenses incurred during the period from September 1, 2024 through and including December 31, 2024 (the "Application Period") in these Chapter 11 Cases. In support hereof, NPM respectfully states as follows: JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

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

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

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

- 4. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains the Proposed Order granting this Application. - Exhibit B contains a summary of work performed and fees incurred organized by category.

1 NPM 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 C contains a summary of expense reimbursement requested organized by nature of the expenses. - Exhibit D contains a summary of work performed and fees incurred organized by the Specific Avoidance Action. - Exhibit E contains time entries with respect to the legal services provided organized by category (as discussed below). - Exhibit F contains expense reimbursements requested.

I. The Individual Debtor's Chapter 11 Case

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

6. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Chapter 11 Case. No examiner has been appointed in the Chapter 11 Case.

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

8. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the Chapter 11 Case of Ho Wan Kwok.

9. By order entered August 2, 2022, the Court authorized NPM's retention as local and conflicts counsel for the Trustee [ECF No. 669] (the "Retention Order") effective as of July 8, 2022, in the Chapter 11 Case. The Retention Order authorizes NPM to be compensated on an

hourly basis and reimbursed for actual and necessary out-of-pocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct.

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

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

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

13. On November 17, 2022, the Court granted Genever (BVI)'s application to retain NPM as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., October 11, 2022 [ECF No. 1107].

14. On October 12, 2020, Genever (US) filed a voluntary petition for relief under chapter 11 of the Bankruptcy 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").

15. On November 3, 2022, the SDNY Bankruptcy Court entered an order [ECF 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.

16. On November 21, 2022, the Court entered an order granting joint administration of the Genever (US) chapter 11 case with the jointly administered cases of the Individual Debtor and

the Genever (BVI) Debtor's chapter 11 case [ECF No. 1141] (the Individual Debtor, Genever (BVI), and Genever (US) may hereinafter be collectively referred to as the "Debtors").

17. On November 30, 2022, the Court granted Genever (US)'s application to retain NPM 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 [ECF No. 1177]. IV. Prior Applications and Monthly Fee Statements

18. NPM sought the reimbursement of expenses incurred in its representation of the Trustee as local and conflicts counsel by application dated April 18, 2023 [ECF No. 1674] (the "Reimbursement Application"), which application was granted by order of this Court dated May 5, 2023, [ECF No. 1769].

19. By application dated June 1, 2023, NPM sought the allowance of fees for the period from the Petition Date through February 28, 2023 (the "First Interim Application") [ECF No. 1851]. The First Interim Application was granted by order of this Court dated June 29, 2023, allowing the Applicant interim compensation in the amount of \$551,718.50 [ECF No. 1966].

20. By application dated August 4, 2023, NPM sought the allowance of fees and reimbursement of expenses for the period from March 1, 2023 through June 30, 2023 (the "Second Interim Application") [ECF No. 2053]. The Second Interim Application was granted by order of this Court dated September 12, 2023, allowing the Applicant interim compensation in the amount of \$357,587.50 and reimbursement of expenses in the amount of \$10,402.59 [ECF No. 2192]. Pursuant to the Court's order granting the Second Interim Application, \$71,517.50 was held back from payment pending further order of the Court, half of which was later released ("Second Fee App Holdback").

21. By application dated October 18, 2023, NPM sought the allowance of fees and reimbursement of expenses for the period from July 1, 2023 through August 31, 2023 (the "Third Interim Application") [ECF No. 2260]. The Third Interim Application was granted by order of this Court dated November 30, 2023, allowing the Applicant interim compensation in the amount of \$280,180.00 and reimbursement of expenses in the amount of \$1,849.10 [ECF No. 2410].

22. By application dated February 19, 2024, NPM sought the allowance of fees and reimbursement of expenses for the period from September 1, 2023 through December 31, 2023 (the "Fourth Interim Application") [ECF No. 2936]. The Fourth Interim Application was granted by order of this Court dated March 20, 2024, allowing the Applicant interim compensation in the amount of \$1,038,670.00 and reimbursement of expenses in the amount of \$34,929.96 [ECF No. 3021], as amended by Amended Order dated March 27, 2024 [ECF No. 3050]. Pursuant to the Court's order granting the Fourth Interim Application, \$203,734.00 was held back from payment pending further order of the Court, half of which was later released ("Fourth Fee App Holdback").

23. By application dated June 25, 2024, NPM sought the allowance of fees and reimbursement of expenses for the period from January 1, 2024 through April 30, 2024 (the "Fifth Interim Application") [ECF No. 3287]. The Fifth Interim Application was granted by order of this Court dated July 26, 2024, allowing the Applicant interim compensation in the amount of \$1,351,385.50 and reimbursement of expenses in the amount of \$17,663.61 [ECF No. 3359]. Pursuant to the Court's order granting the Fifth Interim Application, \$135,138.55[2] was held back from payment pending further order of the Court ("Fifth Fee App Holdback").

2 Additionally, pursuant to the order granting the Fifth Interim Application, NPM was paid fifty (50%) percent of the Second Fee App Holdback and Fourth Fee App Holdback. Moreover, NPM reserved the right to seek compensation for fees in the amount of \$5,341.50 associated with services related to Despins, Chapter 11 Trustee v. Hing Chi Ngok, et al. (Adv. Proc. No. 24-05273) (the "Civil RICO Action") during the application period of the Fifth Interim Application.

24. By application dated October 15, 2024, NPM sought the allowance of fees and reimbursement of expenses for the period from May 1, 2024 through August 31, 2024 (the "Sixth Interim Application") [ECF No. 3702]. The Sixth Interim Application was granted by order of this Court dated November 13, 2024 [ECF No. 3815] as amended by Amended Order dated November 20, 2024, allowing the Applicant interim compensation in the amount of \$1,254,303.00 and reimbursement of expenses in the amount of \$22,876.71 [ECF No. 3842]. Pursuant to the Court's order granting the Sixth Interim Application, \$125,430.30[3] was held back from payment pending further order of the Court ("Sixth Fee App Holdback" and together with the Second Fee App Holdback, the Fourth Fee App Holdback, and the Fifth Fee App, the "Prior Holdbacks").

25. On November 26, 2024, pursuant to the Interim Compensation Procedures Order, NPM filed its *Monthly Fee Statement for Compensation and Reimbursement of Expenses for Period from September 1, 2024 Through September 30, 2024* [ECF No. 3850] (the "September Monthly Fee Statement") attaching NPM's itemized fees for the month of September, 2024 and requesting payment of 80% of all fees for services rendered and 100% of all expenses incurred for such month (i.e., \$260,268.40 in fees and \$5,762.40 in expenses). After discussions with the Office of the United States Trustee, NPM agreed to a voluntary reduction of \$7,500.00 of the fees requested in its September Monthly Fee Statement.[4] No objections were filed to NPM's September Monthly Fee Statement and the amounts requested for payment, adjusted for the \$7,500.00 voluntary fee reduction, were paid on December 23, 2024.

3 Additionally, NPM reserved the right to seek compensation for fees in the amount of \$6,467.00 associated with services related to the Civil RICO Action during the application period of the Sixth Interim Application.

4 NPM includes this voluntary reduction in the \$20,000.00 voluntary reduction that NPM has assessed with respect to this Application.

26. NPM did not file a Monthly Fee Statement for the months of October 2024 through December 2024 and has included its itemized fees and expenses for the months of October 2024 through December 2024 in this Application. SEVENTH INTERIM FEE APPLICATION OF PAUL HASTINGS LLP AND INCORPORATION BY REFERENCE

27. Paul Hastings LLP ("Paul Hastings") is lead counsel to the Trustee, Genever (BVI), and Genever (US) in these Chapter 11 Cases. As discussed herein, throughout the course of these Chapter 11 Cases, NPM has worked cooperatively with Paul Hastings as Connecticut counsel and conflicts counsel to the Trustee and as co-counsel with respect to Genever (BVI) and Genever (US) (collectively, the "Genever Debtors").

28. On February 24, 2025, Paul Hastings filed its *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* [ECF No. 4157] (the "PH Application"). The PH Application contains extensive discussion of the history of these Chapter 11 Cases and the nature of legal services performed for the Trustee and the Genever Debtors. To avoid repetition, NPM incorporates the PH Application herein by reference.

29. In the interest of efficiency and reducing administrative expense, throughout the Trustee's investigation and asset-recovery efforts, and the administration of these Chapter 11 Cases, the Trustee and Paul Hastings have requested and NPM has performed legal services with respect to substantive, administrative, and procedural issues (e.g., preparing, reviewing and revising pleadings, presenting and arguing discovery motions, serving subpoenas and court orders, requesting adjournments and approving stipulations, preparing monthly operating reports, interacting with clerks' offices and chambers and coordinating logistics for hearings, and attending to other case administration functions as they arise). NPM's counsel have also advised with respect Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 11 of 373

to this district's local rules and practices and has assisted the Trustee at court hearings throughout these Chapter 11 Cases.

30. This support has both ensured that the Trustee and the Genever Debtors understood and complied with local rules and practices—and has also resulted in substantial administrative cost savings in these Chapter 11 Cases.

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

32. For the Application Period, the Applicant seeks allowance of fees in the amount of \$1,075,419.00, as compensation for services rendered in connection with such services. This amount reflects (a) a \$20,000.00 voluntary reduction, which NPM has assessed as a courtesy to the Trustee, the Genever Debtors, and the bankruptcy estates; and (b) that NPM is not presently requesting allowance of its fees (in the amount of \$12,800.00) incurred with respect to the Civil RICO Action, provided, however, NPM reserves the right to request allowance and payment of such fees in the future.

33. The Applicant devoted 2,453.50 hours to this case during the Application Period, equating to an overall blended rate of \$446.20.

34. Throughout the Application Period, the Applicant maintained records to indicate the name of each attorney or paraprofessional working on this matter, the time spent on a particular issue, and the nature of the work performed. These records, which describe in detail the services rendered by the Applicant, were created at the approximate time the services were performed. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 12 of 373

35. Annexed hereto and made a part hereof as Exhibit E is a detailed billing report, broken down by project category, upon which this application is based that contains each individual professional's time for the Debtors' bankruptcy proceedings, itemizing the dates upon which services were rendered, including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the dollar value of such services. A summary of the foregoing is attached hereto as Exhibit B.

36. Annexed hereto and made a part hereof as Exhibit F is a detailed report of costs and expenses incurred by the Applicant during the Application Period. A summary of the foregoing is attached hereto as Exhibit C.

37. During the Application Period, the following summarizes the services provided by the Applicant on behalf of the Trustee:

a. advising the Trustee as to his investigation into the property of the Individual Debtor's estate (the "Estate"), including his pursuit of actions to collect and recover property for the benefit of the Estate;

b. commencing, conducting, and/or continuing litigation necessary and appropriate to assert rights held by the Estate, protect assets of the Estate, or otherwise further the goal of completing the Chapter 11 Case;

c. preparing and reviewing, on behalf of the Trustee, necessary and appropriate applications, motions, proposed orders, other pleadings, notices, schedules, and other documents, and reviewing financial and other reports filed and to be filed in the Chapter 11 Case; Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 13 of 373

d. advising the Trustee concerning, and preparing responses to, applications, motions, other pleadings, notices, and other papers that may be filed by other parties in the Chapter 11 Case;

e. reviewing the nature and validity of any liens asserted against the property in these Chapter 11 Cases and advising the Trustee concerning the enforceability of any liens;

f. assisting the Trustee in the investigation, recovery, marketing, and disposition of estate assets; and

38. During the Application Period, the following summarizes the services performed by the Applicant as counsel to the Genever Debtors:

a. preparing, reviewing, and revising the monthly operating reports for the Genever Debtors; and

b. corresponding with the Genever (BVI) Director, the U.S. Trustee's office, the Trustee, and co-counsel regarding the monthly operating reports for the Genever Debtors. CATEGORIZATION OF SERVICES AND CATEGORY SUMMARIES

39. As is its practice as counsel to trustees or debtors in chapter 11 cases, NPM has organized its time by category in respect to the nature of the services it provided to the Trustee and the Genever Debtors. All services provided to the Genever Debtors fell within the Case Administration category, and thus this category is divided between services provided to the Trustee and to the respective Genever Debtors. More specifically, the services provided under each category and NPM's summaries of same are as follows: A. Case Administration: Fees: \$6,853.50; Total Hours: 19.30; Cumulative Prior Fees: \$79,752.00[5]

40. During the Application Period, NPM prepared and filed appearances in multiple adversary proceedings and reviewed an annual report prepared by the Genever (BVI) Director. In addition, NPM conducted conflict searches regarding multiple interested parties and prepared operating reports on behalf of the Genever Debtors, including those for August, September, October and November 2024. In connection with these operating report services, NPM communicated with the Genever (BVI) Director, the Trustee, and co-counsel at Paul Hastings regarding issues related to the operating reports, and bank statements for the Genever (US) account. B. Asset Disposition: Fees: \$52,184.00; Total Hours: 105.3; Cumulative Prior Fees: \$41,831.00

41. NPM performed services to assist the Trustee with liquidating assets for the benefit of the Estate. Prior to this Application Period, NPM successfully obtained a summary judgment order finding that Greenwich Land's assets and Ms. Ngok's membership interest in Greenwich Land is property of the Estate on the basis of beneficial ownership. [Adv. Proc. 23-5005 ECF No. 134]. Greenwich Land's primary asset included a 12,000 square foot home located at 373 Taconic Road, Greenwich Connecticut (the "Greenwich Property"). During this Application Period, NPM prepared a motion to sell the Greenwich Property, which the Court granted on October 15, 2024. [Docket 22-50073 ECF Nos. 3592, 3690]. In connection with the foregoing asset sale, NPM provided numerous services related to the preparation of the asset sale, including work with the Trustee to address maintenance and repair needs, securing insurance for the property, and engaging

5 "Cumulative Prior Fees" as stated herein describe cumulative fees incurred during all prior application periods and do not include fees incurred during the Application Period at issue in this Application. The description of prior cumulative fees is included, at the request of the United States Trustee, for informational purposes only and may not reflect all prior adjustments (including write-offs and discounts). Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 15 of 373

in negotiations with auctioneers to sell motor vehicles and other assets located at the Greenwich Property.

42. Likewise, during the Application Period, NPM attorneys worked with the Trustee regarding the maintenance and marketing of the castle-style estate located at 675 Ramapo Valley Road, Mahwah, New Jersey 07430 ("Mahwah Mansion"). These services included interviewing and engaging real estate agents in New Jersey, negotiations concerning the terms of listing agreements and terms for the marketing the property for sale. NPM counsel also collaborated with contractors to ensure necessary repairs were completed and coordinated with the realtors to address property-related inquiries. C. Asset Analysis and Recovery: Fees: \$291,726.00; Total Hours: 644; Cumulative Prior Fees: \$1,941,914.50

43. NPM assisted the Trustee in investigating, preserving, and recovering assets for the benefit of the Estate.

44. As part of its investigation, NPM has sought information on assets and transactions around the globe. During the Application Period, NPM served numerous Bankruptcy Rule 2004 orders and subpoenas on financial institutions, banks, affiliated entities and individuals located in the United States, China and various countries around the world to investigate transactions and recover assets for the benefit of the Debtors' estates.

45. Throughout the Application Period, NPM worked with Paul Hastings to prepare supplemental motions under Bankruptcy Rule 2004 seeking discovery from various individuals and entities. Specifically, NPM prepared, filed and prosecuted the seventeenth supplemental Bankruptcy Rule 2004 application, and substantially prepared the eighteenth supplemental omnibus Bankruptcy Rule 2004 application (which was filed after the Application Period) [Docket 22-50073 ECF. Nos. 3594, 3981]. NPM also assisted Paul Hastings in the preparation, filing, and Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 16 of 373

prosecution of the Bankruptcy Rule 2004 application directed at Schulman Bhattacharya LLP Docket 22-50073 ECF No. 3758].

46. NPM took the lead in litigating objections and motions to quash filed by entities and individuals associated with the Debtor related to the Trustee's Bankruptcy Rule 2004 discovery. Specifically, during the Application Period, NPM litigated an objection to the Trustee's 17th omnibus Bankruptcy Rule 2004 application filed by Bofang Investment LLC and Feibo Jiang [Docket No. 22-50073 ECF No. 3648], including filing a reply to such objection [Docket No. 22- 50073 ECF No. 3767], following which the Court overruled the objection [Docket No. 22-50073 ECF No. 3823]. Similarly, NPM objected to a motion to quash filed by Yumei Hao, River Valley Operations, and Golden Eagle Ventures (addressing subpoenas issued pursuant to the Trustee's 16th omnibus Bankruptcy Rule 2004 Application), which resulted in a stipulation resolving this discovery dispute in favor of the Trustee [Docket No. 22-50073 ECF No. 3791]

47. NPM worked in conjunction with Paul Hastings to prepare, issue, and enforce compliance with subpoenas with respect to the above-mentioned motions and prior Bankruptcy Rule 2004 Motions. Specifically, NPM devoted substantial efforts to manage subpoenas directed at the over twenty financial institutions, including but not limited to, the Bank of China, Old National Bank, Comerica Bank, U.S. Bank, IDB Bank, First Bank of Greenwich, AmEx, China CITIC Bank International, Rockland Trust, Lake City Bank, Israel Discount Bank, and Citizens Bank. Moreover, NPM played a critical role in coordinating with the subpoenaed parties to streamline the process, facilitating the production of numerous documents. By meeting and conferring with counsel for many subpoena targets, NPM was often able to narrow or resolve objections to the Trustee's Bankruptcy Rule 2004 subpoenas and thus to obtain information useful to the Trustee's investigation and valuable to the Estate without litigation. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 17 of 373

48. In addition to obtaining production from subpoena targets, NPM assisted in reviewing and analyzing documents and information produced by subpoena targets. Further, NPM worked closely with professionals from Kroll, LLC ("Kroll"), the Trustee's forensic investigator, in order to ascertain further entities and subjects requiring investigation and to identify and close any "gaps" within the universe of documents and information obtained by the Trustee to date. NPM and Kroll also worked cooperatively to facilitate analysis of the documents and information obtained in the Trustee's Bankruptcy Rule 2004 investigations—which analysis has been leveraged in preparing and prosecuting the Trustee's litigation claims. To date, NPM has worked directly with Kroll to identify approximately 745 Debtor-associated accounts and 203,500 transactions in and out of these accounts. The investigation has revealed that the transactions collectively amount to \$10 billion dollars.

49. Furthermore, NPM collaborated with the Trustee to obtain additional information elucidated in connection with the Debtor's criminal proceedings since the Debtor's conviction in July 2024. During this Application Period, NPM obtained the Debtor's criminal case records which facilitated the identification of additional estate assets, defendants, and potential recovery streams for the estate.

50. In the prior fee application period, NPM attorneys and the Trustee obtained a Court ruling to preserve digital property of the Estate from Google and Microsoft, primarily cloud-based email servers associated with domains apparently utilized by the Debtor's alter-egos Lamp Capital, LLC and Golden Spring, LLC. [Docket No. 22-50073 ECF No. 3444]. In the Application Period, NPM pursued efforts to secure access to these email domains, including attending meet-and-confer sessions with counsel to obtain non-content information about the account administrators. NPM conducted extensive legal research on decisions regarding permissible scope of non-content Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 18 of 373

disclosures, drafted a subpoena tailored to obtain such information, and engaged in additional meet-and-confer discussions with Microsoft's counsel to compel compliance. D. Avoidance Action Analysis: Fees \$133,638.00; Total Hours: 342.7; Cumulative Prior Fees: \$1,123,791.50

51. To date, NPM has worked with the Trustee, Kroll, and Paul Hastings to commence over 300 actions (the "Avoidance Actions") on or shortly before the time limitations set forth in the Bankruptcy Code to commence additional avoidance actions and the Court's orders extending such time limitations. On February 15, 2024, the Court extended the statute of limitations to commence additional avoidance actions from February 15, 2024, to August 15, 2024. Subsequently, on July 19, 2024, the Trustee filed the First Supplemental Motion to Extend the August 15, 2024, deadline [Docket No. 22-50073 ECF No. 3329]. The Court granted said motion and extended the time to file additional avoidance actions through and including February 15, 2025 [Docket No. 22-50073 ECF No. 3417].

52. During this Application Period and as a result of the Court's orders extending the applicable statutes of limitations set forth in the Bankruptcy Code, NPM investigated and filed five additional Avoidance Actions during the Application Period and continued to actively litigate previously filed actions. NPM undertook key tasks to advance these actions, including:

a. Extensive review and analysis of the Individual Debtor's financial transactions undertaken via his alter egos. In consultation with Kroll and Paul Hastings, NPM also investigated the business affairs of defendants in Avoidance Actions and the connections between such entities and individuals and the Individual Debtor (including his alter egos). NPM used this investigation and analysis to advise the Trustee and pursue additional Avoidance Actions. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 19 of 373

b. During the Application Period, NPM attorneys drafted and filed five Avoidance Action complaints arising from alleged fraudulent transfers and/or unauthorized postpetition transfers under the Bankruptcy Code and applicable state laws. This involved further analysis of avoidance claims to prepare complaints based upon the following: the applicable alter egos, the unauthorized prepetition and postpetition transfer amounts, as well as claims (prepetition, postpetition, or both) in the various Avoidance Actions. NPM prepared both sealed and unsealed versions of said complaints and appropriately handled confidential information contained therein.

c. During the Application Period, NPM attorneys served the Trustee's new Avoidance Action complaints within the United States and, as to both new and existing Avoidance Action complaints, worked with Paul Hastings and other counsel for the Trustee in foreign countries to accomplish service of the Trustee's new and existing Avoidance Action complaints throughout the world. In connection with this task, NPM attorneys assisted with researching information necessary to serve the corresponding summons and complaint, analyzing whether service was properly effectuated, and the drafting of many dozens of affidavits of service.

d. After the Avoidance Actions were filed and served, NPM filed applicable notices, appearances and certificates of service. NPM also analyzed potential defenses to these actions. Notably, NPM collaborated with Paul Hastings to prepare and file eight objections to defendants' motions to dismiss in pending Avoidance Actions. NPM took the lead in drafting many of these oppositions and worked collaboratively with Paul Hastings throughout the process. NPM also took the lead in drafting oppositions to several motions to withdraw the reference with respect to pending Avoidance Actions. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 20 of 373

e. During the Application Period, as part of NPM's efforts to recover assets for the Trustee, NPM attorneys attended numerous court hearings related to the applicable procedures and prosecution of the Avoidance Actions. Prosecution of the Avoidance Actions also included preparing and filing amended complaints, responding to motions to dismiss, and addressing confidentiality issues. Moreover, NPM attorneys analyzed the Avoidance Actions to address non-responsive defendants and prepared numerous requests for entry of defaults, which were subsequently granted.

f. In consultation with the Trustee, NPM attorneys assisted Paul Hastings attorneys in litigating confidentiality and procedural issues in connection with the Trustee's submission of proposed settlements for Court approval. These matters were submitted to the Court in connection with the Trustee's proposed settlement with Wildes and Weinberg, P.C. (the "W&W Settlement"). During the Application Period, NPM attorneys finalized and filed the motion to approve the W&W Settlement, as well as a motion to limit notice with respect to same, and assisted Paul Hastings attorneys in litigating disputed confidentiality matters with the United States Trustee and G Club Operations LLC, which resulted in a compromise resolution with the United States Trustee and a contested hearing with Club Operations LLC, followed (after the Application Period) by the Court's decision approving the compromise with the United States Trustee and overruling G Club's objection.

g. In consultation with the Trustee, NPM attorneys negotiated, prepared and entered into Tolling Agreements with parties which provided the Trustee and the tolling parties additional time to review and discuss the resolution of claims without the costs associated with ongoing litigation. The Tolling Agreements were approved by the Court

after submission under seal by NPM. As a result of the Tolling Agreements, NPM successfully negotiated, prepared and filed settlement agreements and stipulated judgments with multiple tolling parties. Because the Court has by this point approved many dozens of tolling stipulations, NPM and Paul Hastings professionals have worked collaboratively to maintain a calendar of tolling deadlines and to negotiate and obtain extensions when appropriate.

h. Significantly, NPM attorneys collaborated with Paul Hastings attorneys in implementing and engaging in a large-scale mediation program, which the Trustee and opposing counsel have utilized to explore resolution of the Trustee's avoidance claims against more than 40 defendants. NPM attorneys have represented the Trustee in these mediation programs to reach or make progress towards settlements with numerous Avoidance Action defendants. NPM attorneys have also represented the Trustee in negotiating settlements of avoidance claims not yet in suit, often with parties that have entered tolling stipulations with the Trustee. When the Trustee has agreed on settlement terms with counterparties (subject to Court approval), NPM attorneys regularly prepared and negotiated the terms of settlement agreements. During the Application Period, NPM attorneys participated in the negotiation of numerous settlements that will (in the aggregate) generate millions of dollars of value for the Individual Debtor's Estate. With the Court's approval now in place of procedures governing confidentiality in the Trustee's submission of proposed settlements, NPM is currently preparing Bankruptcy Rule 9019 motions by which many of these settlements will be submitted for Court approval. [6]

6 To preserve confidentiality, NPM has redacted from the time records attached to this Application much of the discussion of settlement negotiations (in particular from those entries regarding settlement negotiations with counterparties that have not been sued by the Trustee and that are counterparties to tolling stipulations). Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 22 of 373

i. Finally, in conjunction with the avoidance actions, NPM attorneys collaborated with Paul Hastings to address numerous appeals filed by avoidance defendants, including appeals regarding the Court's orders extending the statutes of limitations to file avoidance actions.

53. In sum, NPM continued to play a crucial role in managing and executing the various tasks involved in commencing and prosecuting Avoidance Actions during the Application Period in order to recover assets for the benefit of the Estate.

54. During the Application Period, NPM separately organized and categorized its time incurred with respect to specific Avoidance Actions by project codes specific to such Avoidance Actions. NPM separately summarizes these services in the summary attached as Exhibit D and the nature of the services is specifically described in NPM's fee statements attached to this Application. NPM has continued to categorize within the general Avoidance Action Analysis category its services performed in connection with (a) all or multiple Avoidance Actions (e.g., services performed in connection with generally applicable mediation procedures), (b) investigating and preparing to commence actions to prosecute avoidance claims, and (c) negotiating with potential avoidance defendants prior to the Trustee commencing suit. E. Fee/Employment App's (Other Than NPM): Fees: \$17,658.00; Total Hours: 37.2; Cumulative Prior Fees: \$193,422.00[7]

55. NPM and the Trustee's efforts to locate and recover the Debtor's assets have necessitated the engagement of attorneys and other professionals across multiple jurisdictions. As a result, NPM attorneys worked with the Trustee and Paul Hastings in the preparation and prosecution of several retention applications and monthly fee statements during the Application

7 Prior to this Application Period, this task code included entries with respect to NPM's retention and fee applications, which are included in the aggregate figure. As of the current Application Period, entries with respect to NPM's retention and fee applications are individually categorized. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 23 of 373

Period including the Trustee's New Jersey counsel Winne, Banta, Basralian & Kahn, P.C. and his real estate brokers for the Greenwich Property, Compass, Inc. and Mahwah Mansion. F. NPM- Fee/Employment App's: Fees: \$30,019.00; Total Hours: 74.3; Cumulative Prior Fees: \$0.00[8]

56. During the Application Period, NPM prepared and prosecuted its Sixth Interim Fee Application, as well as its September Monthly Fee Statement [Docket No. 22-50073 ECF Nos. 3702, 3850]. NPM professionals also undertook supplemental conflicts and disinterestedness analyses and substantially drafted a supplemental declaration with respect to NPM's disinterestedness, which it intends to file shortly. G. Adversary Proceedings (and Related Appeals):

57. During the Application Period, NPM attorneys worked with Paul Hastings attorneys in the prosecution of both adversary and appellate proceedings. More specifically, NPM counsel performed the following services: (i) Greenwich Land Adv. Proc. 23-5005: Fees: \$77,191.00; Total Hours: 177.00; Cumulative Prior Fees: \$62,670.00

58. This adversary proceeding (the "Greenwich Land A.P.") concerns the Trustee's claims against Greenwich Land LLC ("Greenwich Land") and Hing Chi Ngok (the Individual Debtor's alleged wife) that the company defendant and its assets are property of the Estate.

59. On July 2, 2024, the Court entered a summary judgement order in the Greenwich Land A.P. [ECF No. 134] finding, among other things, that Greenwich Land was property of the Individual Debtor's estate. Shortly thereafter, Hing Chi Ngok vacated the Greenwich Property and the Trustee obtained possession of property on behalf of the Estate.

8 See footnote 7. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 24 of 373

60. During this Application Period, NPM worked with the Trustee to facilitate the marketing and sale of the Greenwich Property. This included NPM's professionals working directly with the Trustee's real estate broker, Compass, Inc., to extensively market the Greenwich Property, coordinate open houses and access to the property, and assist with the bidding process. Other services included advising the Trustee regarding proposals to purchase the Greenwich Property, the negotiation and preparation of all purchase and sales agreements, and notifying the Court of potential buyers and purchase and sale agreements.

61. In connection with the sale of the property, NPM attorneys worked with the Trustee to finalize and file his motion to authorize the sale of the Greenwich Property on an expedited basis [Docket No. 22-50073 ECF No. 3592]. On October 15, 2024, the Court granted the motion [Docket No. 22-50073 ECF No. 3690]. Shortly after entry of the sale order, NPM attorneys worked with the Trustee and buyer successfully closed on the sale transaction, resulting in \$6,900,000.00 of sale proceeds recovered by the Estate.

62. Following the sale of the Greenwich Property, NPM attorneys continued to work with the Trustee to seek to retain an auctioneer to sell motor vehicles and other assets located at the Greenwich Property [Docket No. 22-50073 ECF No. 3504]. (ii) HK USA/Interpleader Adv. Proc. 22-5003, 23-5012: Fees: \$3,987.00; Total Hours: 8.3; Cumulative Prior Fees: \$46,785.00

63. This adversary proceeding (the "HK USA/ Interpleader Adversary Proceeding") relates to the possession of the Debtor 's escrow funds in connection with the Debtor's yacht "Lady May". Previously, the Court granted the Trustee's motion for summary judgment against the defendants and cross-defendants asserting that the escrow funds held by U.S. Bank should be disbursed to the Trustee. Defendants' and cross-defendants' appealed the Court's decision. [Docket No. 22-5003 No. 221]. Throughout this Application Period, NPM performed all tasks Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 25 of 373

related to representing the Trustee in the cross-defendants' Second Circuit appeal of the Court's summary judgment decisions (following the cross-defendant's unsuccessful District Court appeal, which affirmed this Court in all respects), including conducting including negotiating a joint appendix for use in the Second Circuit appeal, addressing procedural filings, and preliminary review and research with respect to matters on appeal. (iii) Sherry Netherland Adv. Proc. 23-5002: Fees \$446.00; Total Hours: 1.0; Cumulative Prior Fees: \$4,344.50

64. This adversary proceeding (the "Sherry Netherland Possession Adversary Proceeding") relates to the possession of the penthouse apartment at the Sherry Netherland Hotel owned by Genever (US). During the Application Period, NPM drafted and filed the Consented Motion to Adjourn Pretrial Conference, which was approved by the Court, setting a new date of February 25, 2025 for the Pretrial Conference [ECF Nos. 82, 87]. (iv) Mei Guo Adv. Proc 23-5008: Fees: \$ 18,792.50; Total Hours: 40.6; Cumulative Prior Fees: \$518,150.00

65. This adversary proceeding (the "Mei Guo/Aircraft Adversary Proceeding") relates to the recovery of the proceeds from the unauthorized postpetition sale of the Bombardier Global XRS private jet with serial number 9189 (the "Bombardier"), held in the name of Whitecroft Shore Limited ("Whitecroft"), a shell company nominally owned by the Individual Debtor's daughter.

66. Prior to this Application Period, the defendant Mei Guo appealed the Court's order granting the Trustee's summary judgment motion, ruling that the Trustee is the beneficial owner of Whitecroft and entitled to the Bombardier's sale proceeds (the "Aircraft Order"). During this Application Period, significant time was devoted to the drafting and filing of the Appellee brief in conjunction with Paul Hastings as well as review of the Appellant Reply Brief. The Court's summary judgment order was affirmed by the District Court on January 21, 2025 [ECF No. 143]. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 26 of 373

67. In addition, during the Application Period, NPM's professionals assisted Paul Hastings professionals in preparing a motion to enforce the preliminary injunction issued by the Court on December 21, 2023 [ECF No. 126]. The Trustee has alleged that Mei Guo has violated the preliminary injunction through continued spending and transferring of assets without Court approval. The motion to enforce the preliminary injunction seeks an order requiring Mei Guo to comply with the preliminary injunction and to show cause why she should not be held in contempt, in addition to other relief [ECF No. 140]. (v) HCHK Adv. Proc. 23-5013: Fees: \$2,772.00; Total Hours: 5.6; Cumulative Prior Fees: \$127,649.00

68. This adversary proceeding (the "HCHK Adversary Proceeding") concerns the "HCHK Entities," i.e., entities that the Trustee believes are alter egos of the Individual Debtor that are in possession of more than \$38 million in assets. During the Application Period, NPM counsel assisted in analyzing and preparing the Trustee's response to the defendants' counsel's motion to withdraw its appearance in this adversary proceeding (including supporting the Trustee's position that, in light of their counsel's withdrawal, the HCHK Entities' appeal then pending in the District Court should be dismissed). On October 2, 2024, following a hearing, the District Court granted the motion to withdraw appearance [Docket No. 3:24-cv-00335-KAD ECF No. 24]. Upon the failure of the HCHK Entities' failure to appear through new counsel by date set by the appellate court, their pending appeal was dismissed on October 24, 2024, with a judgment of dismissal entered on November 11, 2024 [Docket No. 3:24-cv-00335-KAD ECF Nos. 25, 51]. (vi) Mahwah Adv. Proc. 23-5017: Fees: \$21,659.50; Total Hours: 52.6; Cumulative Prior Fees: \$61,188.00

69. This adversary proceeding (the "Mahwah Adversary Proceeding") concerns a luxury residential estate (the "Mahwah Mansion") located in Mahwah, New Jersey, and the Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 27 of 373

Trustee's claims that, among other things, this asset is property of the Estate. Prior to this Application Period, NPM attorneys assisted in the preparation and filing of an adversary proceeding against Taurus Fund, Scott Barnett, and Taurus Management LLC, to determine that the Individual Debtor's Mahwah Mansion is property of the Estate [ECF No. 1].

70. During this Application Period, NPM assisted in discovery matters, and in the preparation and prosecution of a motion for summary judgment [ECF No. 124].

71. Upon the defendant's violation of a preliminary injunction order requiring them (among other things) to adequately insure the Mahwah Mansion, NPM collaborated with the Trustee to draft and file a motion seeking authorization to market and sell the Mahwah Mansion and its contents and to take steps in furtherance thereof, including the retention of a real estate broker to facilitate the sale. On October 29, 2024, the Court granted said motion. [ECF Nos. 134, 142]. (vii) Golden Spring Adv. Proc. 23-5018: Fees: \$3,840.00; Total Hours: 8.0; Cumulative Prior Fees: \$26,194.50

72. This adversary proceeding (the "Golden Spring Adversary Proceeding") concerns the Trustee's claims that Golden Spring (New York) Ltd. (the "Golden Spring") is the Individual Debtor's alter ego or is beneficially owned by the Individual Debtor. Prior to the Application Period, the Court granted the Trustee's default judgment against the defendants.

73. On November 7, 2024, NPM issued a subpoena for the production of documents and information upon Microsoft Corporation. Subsequently, NPM attorneys have been in communications with counsel for Microsoft Corporation regarding compliance with the subpoena. (viii) Lamp Capital Adv. Proc. 23-05023: Fees: \$2,961.00; Total Hours: 7.9; Cumulative Prior Fees: \$21,224.00

74. In this adversary proceeding (the "Lamp Capital Adversary Proceeding"), the Trustee sought, among other things, declaratory relief to the effect that Lamp Capital LLC ("Lamp Capital"), Infinity Treasure Management Inc. ("Infinity"), Hudson Diamond NY LLC, and Leading Shine NY Ltd, and their respective assets, are property of the Estate.

75. During the Application Period, NPM counsel assisted Paul Hastings attorneys in the preparation and prosecution of a motion for summary judgment against the defendants Hudson Diamond NY, LLC, and Leading Shine, NY Ltd. [ECF No. 97]. This motion remains sub judice, with the Court's determination pending. (ix) Ace Decade Adv. Proc 23-5028 Fees: \$297.00; Total Hours: 0.6; Cumulative Prior Fees: \$32,759.50

76. In this adversary proceeding (the "Ace Decade Holding Limited Adversary Proceeding") the Trustee seeks to set aside the transfer of the ownership of Ace Decade Holdings Limited ("Ace Decade"), which the Court has found is beneficially owned by the Individual Debtor, by Yanping ("Yvette") Wang to Rui Hao. During the Application Period, NPM performed services relating to the Trustee's motion for default judgment against defendant Rui Hao. In connection with the foregoing, on September 12, 2024, the Court granted the Trustee's Entry of Default Judgment against defendant Rui Hao [ECF No. 82]. (x) Civil RICO Adv. Proc. 24-05273 Fees: \$12,800.00; Total Hours: 30.2; Cumulative Fees: \$11,808.50

77. NPM is not requesting allowance of fees for services performed with respect to the Civil RICO Action at this time but will do so in the future and will discuss its services in this action at that time. (xi) ACA Capital Group Adv. Proc. 24-05249 Fees: \$15,675.00; Total Hours: 34.3; Cumulative Prior Fees: \$22,400.00

78. In this adversary proceeding (the "Omnibus Alter Ego Adversary Proceeding") the

Trustee seeks, among other things, declaratory relief to the effect that twenty-five entities[9] are alter egos of the Individual Debtor and/or that the Individual Debtor beneficially owned these entities such that the entities and their assets are property of the Estate. During the Application period, NPM worked in collaboration with Paul Hastings to draft and file a request for entry of default against certain defendants, which was entered by the Court [ECF Nos. 54, 94]. This request for entry of default involved demonstrating proper service of numerous entities throughout the world under multiple international service regimes. Moreover, NPM attorneys assisted Paul Hastings in the preparation and filing of an omnibus objection to motions to dismiss [ECF No. 121], which is currently under advisement by the Court. (xii) Defang Cao, Adv. Proc. 24-05001 Fees: \$8,886.00; Total Hours: 18.5; Cumulative Prior Fees: 1,761.00

79. In this adversary proceeding, the Trustee has sued Defang Cao, a close associate of the Debtor and the Debtor's daughter, to obtain several vehicles transferred to Mr. Cao. During this Application Period, the Trustee requested discovery from several vehicle dealers in connection with the Trustee's claims in this adversary proceeding.

9 The 25 Defendants are: ACA Capital Group Ltd., Alfa Global Ventures Limited, Alfonso Global Ventures Limited, Anton Development Limited, Bravo Luck Limited, China Golden Spring Group (Hong Kong) Ltd., Eastern Profit Corporation Limited, Freedom Media Ventures Limited, G Club International Limited, G Club Operations LLC, G Fashion (CA), G Fashion Hold Co A Limited, G Fashion Hold Co B Limited, G Fashion International Limited, GFashion Media Group Inc., G Music LLC, GF IP, LLC, GF Italy, LLC, GFNY, Inc., Hamilton Capital Holding Limited, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Haoran Ge, Himalaya Currency Clearing Pty Ltd., Himalaya International Clearing Limited, Himalaya International Financial Group Limited, Himalaya International Payments Limited, Himalaya International Reserves Limited, Jovial Century International Limited, K Legacy Ltd., Karin Maistrello, Leading Shine Limited, Major Lead International Limited, Qiang Guo, Rule of Law Foundation III Inc., Rule of Law Society IV, Inc., Saraca Media Group, Inc., Seven Mission Group LLC, William Je, and Wise Creation International Limited (xiii) Bouillor Holdings Limited, et al. Adv. Proc. 24-05311 Fees: \$6,602.50; Total Hours: 15.7; Cumulative Prior Fees: \$1,683.00

80. In this adversary proceeding (the "Bouillor Holdings Adversary Proceeding") the Trustee seeks to recover the Individual Debtor's luxurious high-rise apartment at Number 23-03 in the "One Limassol" building in Limassol, Cyprus (the "Cyprus Apartment"), held in the name of Bouillor Holdings Limited ("Bouillor"), a Cyprus entity nominally owned by Qiang Guo, the Individual Debtor's son.

81. During the Application Period, NPM counsel, in consultation with Paul Hastings, prepared the Trustee's motion to request an entry of default against the defendants, Bouillor Holdings Limited, Qiang Guo, Mei Guo, and New Dynamic Development Limited, which was granted on December 10, 2024. [ECF Nos. 14, 15]. (ix) Specific Avoidance Actions: Fees: \$400,231; Total Hours: 860.6

82. As noted above, since March 2024, NPM has separately categorized its fees incurred in pending Avoidance Actions. The foregoing fees and hours represent the aggregate of time devoted to the prosecution of specific Avoidance Actions during the Application Period.

83. Among other things, NPM attorneys (a) negotiated with counsel for defendants in Avoidance Actions regarding extensions of time to respond to the Trustee's complaints, (b) engaged in settlement discussions, (c) assisted in organizing and attending mediation sessions, (d) investigated and researched claims and defenses in pending Avoidance Actions, (e) prepared amended complaints in two Avoidance Actions, (f) drafted and filed objections to defendants' motions to dismiss in eight Avoidance Actions; and (g) drafted and filed objections to defendants' motions to withdraw the reference with respect to Avoidance Actions. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 31 of 373

84. The Trustee's services specific to pending Avoidance Actions are discussed in greater detail in the summary attached hereto as Exhibit D.

85. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee and Genever Debtors in connection with the chapter 11 proceedings herein.

86. NPM respectfully submits that its services have benefited the Trustee and the Genever Debtors with the expertise and skill required in the handling of bankruptcy matters. The legal services for which such compensation is requested were performed for and on behalf of the Trustee and the Genever Debtors. Such services have been necessary to protect and enforce the rights and interests of the Trustee and the Genever Debtors in connection with the Chapter 11 Cases. The reasonable value of services rendered by NPM in these proceedings is based upon NPM's usual hourly rates for matters of this nature.

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

88. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code provides that, after notice and a hearing, the Court may award a professional employed under 11 U.S.C. § Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 32 of 373

327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).[10]

89. 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 Communications Systems, Inc., 395 B.R. 512, 516 (D. Conn. 2008).

90. 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. 488 F.2d 714 (5th Cir. 1974) (abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87 [1989]), [11] while also bearing in mind that a "reasonable, paying client wishes to spend the minimum necessary to litigate the case effectively." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections, 522 F.3d 182, 190 (2d Cir. 2007). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544 F.2d

10 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).

11 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 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 33 of 373

1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.[12] 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").

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

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

93. NPM 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

12 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).

pertaining to this engagement that were provided during the Application Period?

Response: No. Question: If the fees sought in this application as compared to the fees budgeted for the Application 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? Response: No. 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 includes 2.0 hours in connection with reviewing/revising time records in connection with monthly fee statements and associated fees of \$1,100 and the Application includes an additional approximately 2.0 hours and associated fees of approximately \$505 in connection with the preparation of monthly fee statements (July and September monthly fee statements were filed during the Application Period). NPM notes that, without obligation to do so, NPM wrote off certain time devoted to reviewing invoices in connection with its monthly fee statements or assessed no charge for such entries, including more than six attorney hours of time (which amounts are over and above the general discount applied by NPM). 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: The Application contains approximately 4.3 hours of time and associated fees of \$1780.50 with respect to time entries devoted to or involving redaction. As to the bulk of the attorney time at issue,

compile exhibits and redact, etc.).

redaction was one of several tasks during the time entry (e.g.,

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 35 of 373

> 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: The Application Period did not include rate increases.

94. There exist Prior Holdbacks of \$398,194.60 (i.e., \$35,758.75 under the Second Fee App Holdback, \$101,867 under the Fourth Fee App Holdback, \$135,138.55 under the Fifth Fee App Holdback and \$125,430.30 under the Sixth Fee App Holdback). NPM consents that the Prior Holdbacks remain in effect.

95. NPM further consents to a holdback of 10% with respect to fees allowed during the current Application Period

96. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or NPM has for any reason not sought compensation or reimbursement with respect to such services, NPM reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these Chapter 11 Cases. Also, NPM 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.

58. No previous request for the relief sought herein has been made to this Court or any other court. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 36 of 373

WHEREFORE, NPM respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of \$1,075,419.00, (ii) allowing compensation for expenses incurred in the amount of \$30,859.27 , (iii) authorizing and directing payment of 90% of the fees and 100% of the expenses allowed and awarded for the Application Period, (iv) allowing such compensation and payment for professional services rendered without prejudice to NPM's right to seek further compensation and/or payment from the Debtors' estates for the full value of services performed and expenses incurred, and/or to seek release of any amounts that remain subject to a holdback, and (v) granting NPM such other and further relief as is just.

Dated: February 24, 2025 New Haven, Connecticut

> By: /s/ Patrick R. Linsey Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 821-2000 dskalka@npmlaw.com plinsey@npmlaw.com

> > Counsel to Luc A. Despins, 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.1 : :

**[PROPOSED] ORDER GRANTING SEVENTH INTERIM APPLICATION OF NEUBERT, PEPE & MONTEITH, P.C., AS LOCAL AND CONFLICTS COUNSEL TO THE CHAPTER 11 TRUSTEE AND AS COUNSEL TO DEBTORS GENEVER HOLDINGS CORPORATION AND GENEVER HOLDINGS LLC FOR ALLOWANCE OF FEES AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM SEPTEMBER 1, 2024 THROUGH DECEMBER 31, 2024**

Upon consideration of the Application [ECF No. \_\_\_] (the "Application") of Neubert, Pepe & Monteith, P.C. ("NPM%") as counsel to the Trustee[2] and the Genever Debtors for seventh interim allowance of compensation and reimbursement of expenses from September 1, 2024 through December 31, 2024; and sufficient notice having been given; and a hearing having been held on \_\_\_\_\_\_\_\_\_ and due consideration having been given to any responses thereto; and sufficient cause having been shown therefor, it is hereby:

1. ORDERED that, pursuant to 11 U.S.C. §§ 330 and 331, the Application is granted as set forth herein and compensation in the amount of \$1,075,419.00 (the "Awarded Fees") and

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

2 Capitalized terms not otherwise defined herein adopt the definitions set forth in the Application. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 39 of 373

reimbursement of expenses in the amount of \$30,859.27 (the "Awarded Expenses") is awarded to NPM, subject to final adjustment and disgorgement in the event all administrative expenses are not paid in full or as provided in the order approving the sale of the Lady May [ECF No. 1953]; and it is further

2. ORDERED that NPM's right to seek allowance in future fee applications of fees associated with services related to the Civil RICO Action shall be reserved; and it is further

3. ORDERED that the Debtors' estates are authorized to pay NPM (a) ninety (90%) of the Awarded Fees (i.e., \$967,877.10) and (b) 100% of the Awarded Expenses, and the remaining 10% of Awarded Fees shall be held back by the Debtors' estates pending further order of this Court; and it is further

4. ORDERED that the Prior Holdbacks (i.e., \$398,194.60) shall remain held back pending further order of the Court; and it is further

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

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

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

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

(Summary of Compensation by Project Category)

Task Code and Project Category Hours Billed Fees Billed

B110 Case Administration 19.30 \$6,853.50 B120 Asset Analysis and Recovery 644.00 \$291,726.00 B130 Asset Disposition 105.3 \$52,184.00 B160 Fee/Employment Applications 37.2 \$17,658.00 B180 Avoidance Action Analysis 342.7 \$133,638.00 B360 NPM -Fee/Employment Applications 74.3 \$30,019.00

L603 HK USA/Interpleader A.P. # # 22-5003, 23-5012 8.3 \$3,987.00

et al.

L953 Bouillor Holdings Limited et al, A.P. # 24-05311 15.7 \$6,602.50 Total of Project Categories for Specific Avoidance Actions 860.6 \$400,231.00

E107 Delivery Services/Messengers \$6,554.04

E118 Litigation Support Vendors \$6,083.50

(Summary of Services of Avoidance Actions) Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 43 of 373

Code Name, Adv.

Controversy Hours Fees Status of Adv. Proc. Outcome Cumulative

05005 \$3,621,268.79 5.20 \$2,449.00 Pending/In Mediation

05006 \$16,958,357.65 .50 \$233.50 Pending/In Mediation

-24-05007 \$498,972.50 2.90 \$1,435.50 Pending/In

-24-05008 \$832,000.75 .20 \$99.00 Pending \$1,899.00

05010 \$550,000.00 4.6 \$2,298.00 Pending/In Mediation

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 44 of 373

24-05013 \$315,892.46 .10 \$42.50 Pending \$42.50

-24-05015 \$264,113.25 2.10 \$1,025.50 Pending/In

05019 \$782,206.77 4.80 \$2,432.50 Pending \$242.50

05020 \$103,806.25 .80 \$396.00 Pending \$2,722.50

24-05023 \$5,360,026.85 4.90 \$2,278.50 Pending

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 45 of 373

-24-05027 \$5,824,236.23 2.60 \$1,050.00 Pending

05030 \$128,246.00 1.30 \$629.50 Pending \$3,326.50

Inc. -24-05031 \$302,807.54 1.20 \$446.50 Pending/In Mediation

05033 \$160,552.85 .40 \$190.00 Pending/In

USA, Inc. -24-05034 \$1,200,487.50 11.70 \$5,644.00 Pending/Settlement

-24-05036 \$2,150,000.00 3.70 \$1,747.50 Pending \$680.50

05038 \$250,497.60 .20 \$85.00 Pending \$42.50 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 46 of 373

05041 \$320,000.00 .20 \$85.00 Pending \$1,068.00

Inc. -24-05042 \$137,225.50 1.70 \$838.50 Pending/In

S.P.A. -24-05043 \$181,590.74 1.60 \$690.00 Pending \$2,493.50

-24-05044 \$182,101.13 .20 \$85.00 Pending/In Mediation

24-05046 \$355,143.59 .40 \$170.00 Pending \$42.50

-24-05047 \$190,870.88 .20 \$85.00 Pending/In Mediation

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 47 of 373

-24-05048 \$126,631.24 .20 \$85.00 Pending/In Mediation

-24-05053 \$115,606.00 2.10 \$1,039.50 Pending/Settlement

05054 \$225,000.00 .70 \$332.50 Pending \$800.00

-24-05055 \$290,000.00 .20 \$85.00 Pending/In Mediation

24-05056 \$296,014.00 31.20 \$15,208.00 Pending/Motion to

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 48 of 373

05057 \$488,416.80 1.60 \$665.00 Pending/In Mediation

24-05058 \$197,548.31 3.90 \$1,916.50 Pending/In Mediation

-24-05059 \$290,789.03 1.0 \$481.00 Pending/In Mediation

L669 Apple, Inc. -24-05060 \$279,160.25 39.8 \$19,127.00 Pending

-24-05063 \$150,000.00 .40 \$80.00 Pending

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 49 of 373

L674 A.Z.

05065 \$177,460.13 .40 \$170.00 Pending \$42.50

-24-05069 \$901,814.18 8.60 \$3,902.00 Pending/In Mediation

-24-05074 \$104,959.63 .80 \$396.00 Pending/In Mediation \$2,164.00

05075 \$331,098.34 .10 \$42.50 Pending \$42.50

05076 \$192,754.58 2.20 \$1,089.00 Pending/Settlement

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 50 of 373

-24-05077 \$5,970,652.51 23.60 \$11,121.00 Pending/In

24-05079 \$104,180.00 .20 \$85.00 Pending \$42.50

-24-05080 \$176,158.17 .40 \$170.00 Pending \$42.50

24-05081 \$209,842.32 .10 \$42.50 Pending \$42.50

-24-05082 \$340,000.00 .60 \$305.00 Pending/In Mediation

-24-05083 \$183,184.73 1.00 \$422.00 Dismissed Dismissed \$3,802.00

-24-05087 \$145,965.60 .10 \$42.50 Pending \$42.50 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 51 of 373

05089 \$150,889.73 .10 \$42.50 Pending \$42.50

Corp. -24-05092 \$865,029.22 .40 \$170.00 Pending/In Mediation \$285.00

05094 \$167,426.48 .40 \$170.00 Pending \$42.50

24-05095 \$696,513.07 1.90 \$860.50 Pending \$577.50

05097 \$198,374.45 .20 \$85.00 Pending \$85.00

05098 \$140,127.57 .20 \$85.00 Pending \$85.00 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 52 of 373

05100 \$887,803.39 1.50 \$728.50 Pending/In Mediation

05101 \$160,144.00 13.30 \$6,402.50 Pending/In

-24-05108 \$112,500.00 1.30 \$635.00 Pending

t, Inc. -24-05109 \$1,912,657.00 1.50 \$825.00 Pending/In Mediation \$12,771.50

-24-05110 \$150,000.00 2.90 \$1,435.50 Pending

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 53 of 373

-24-05112 \$535,695.51 .40 \$184.00 Pending/In Mediation

Inc. -24-05114 \$646,730.55 .40 \$185.00 Pending/In Mediation

05115 \$740,727.00 9.10 \$4,154.50 Pending/In

Inc. -24-05117 \$593,350.62 51.8 \$25,170.00 Pending

24-05119 \$140,000.00 .50 \$237.50 Pending/In Mediation \$1,398.00 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 54 of 373

-24-05120 \$254,651.08 8.20 \$3,787.00 Pending/Settlement

05121 \$775,000.00 .40 \$170.00 Pending \$170.00

05122 \$592,858.50 .40 \$170.00 Pending/In Mediation \$141.50

05125 \$238,859.78 2.90 \$1,245.00 Pending \$255.00

05127 \$104,502.03 .20 \$85.00 Pending \$42.50

Inc. -24-05128 \$294,306.00 .40 \$184.00 Pending/In Mediation/

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 55 of 373

nt, Inc. -24-05130 \$123,192.00 .40 \$185.00 Pending

05132 \$109,555.10 .10 \$20.00 Dismissed Dismissed \$3,154.00

P.A. -24-05134 \$746,422.23 .30 \$148.50 Pending

t Corp. -24-05135 \$347,876.13 31.2 \$15,296.50 Pending

24-05136 \$270,202.14 .20 \$85.00 Pending \$1,216.50

05138 \$289,880.00 .20 \$85.00 Pending/In Mediation

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 56 of 373

05141 \$100,775.00 .20 \$85.00 Pending

24-05142 \$260,851.95 1.10 \$492.50 Pending \$492.50

05144 \$1,102,962.00 1.30 \$643.50 Pending \$643.50

Motors, Inc. -24-05145 \$736,057.51 .20 \$99.00 Pending \$1,355.00

05147 \$104,691.25 .20 \$85.00 Pending/In Mediation

-24-05152 \$1,978,250.25 9.60 \$4,597.50 Pending/In

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 57 of 373

24-05154 \$319,186.25 3.60 \$1,770.00 Pending \$12,587.50

-24-05158 \$175,944.65 .40 \$198.00 Pending \$5,614.00

24-05159 \$1,208,067.10 .30 \$127.50 Pending \$127.50

-24-05162 \$258,115.83 2.10 \$1,026.50 Pending/In Mediation

24-05163 \$600,354.99 65.2 \$31,189.50 Pending

-24-05168 \$240,000.00 1.10 \$409.50 Pending

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 58 of 373

-24-05175 \$1,380,813.74 .20 \$85.00 Pending \$85.00

Capital Ltd. -24-05179 \$3,723,302.12 4.50 \$1,767.50 Pending \$1,767.50

-24-05182 \$112,650.36 1.00 \$475.00 Pending \$1,953.50

-24-05183 \$1,462,244.60 .50 \$159.00 Dismissed Dismissed \$8,037.00

24-05185 \$138,515.00 1.20 \$660.00 Pending/In Mediation \$2,106.50

24-05186 \$541,065.45 86.5 \$40,279.50 Pending/Motion to

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 59 of 373

05187 \$115,600.00 7.60 \$3,436.50 Settled \$70,000.00 \$445.50

-24-05188 \$585,655.80 25.4 \$11,610.00 Pending

05190 \$544,375.00 .90 \$445.50 Pending/In Mediation \$1,238.50

24-05193 \$14,083,040.90 .30 \$127.50 Pending \$2,434.00 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 60 of 373

-24-05194 \$110,000.00 3.10 \$1,387.00 Pending/In Mediation

24-05196 \$992,535.80 .20 \$85.00 Pending/In Mediation

-24-05199 \$1,560,260.90 3.20 \$1,584.00 Pending

24-05200 \$161,996.00 1.00 \$318.00 Pending \$523.50

-24-05202 \$882,412.78 .20 \$85.00 Pending/In Mediation/

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 61 of 373

24-05203 \$2,398,593.74 .2 \$85.00 Pending \$85

Kong) Ltd.

24-05204 \$311,476.71 20.2 \$9,409.00 Pending

24-05206 \$515,502.72 3.20 \$1,270.00 Pending \$198.00

-24-05207 \$2,127,500.00 2.30 \$1,138.50 Pending/In Mediation \$610.00

-24-5211 \$832,640.10 .40 \$185.00 Pending/In Mediation

05212 \$100,917.81 .10 \$42.50 Pending \$42.50 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 62 of 373

05213 \$390,747.00 .30 \$141.50 Pending \$787.50

-24-05214 \$925,489.90 .60 \$230.00 Pending/In Mediation \$372.50

24-05216 \$137,971.29 1.60 \$590.00 Pending \$42.50

-24-05219 \$353,269.23 .90 \$445.00 Pending

-24-05221 \$1,775,000.00 2.60 \$1,217.00 Pending \$365.50 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 63 of 373

Corp. -24-05222 \$154,545.17 4.60 \$2,264.00 Pending/In Mediation

05223 \$893,320.00 1.00 \$440.00 Pending \$440.00

-24-05225 \$3,915,140.00 47.5 \$22,400.00 Pending/In Mediation

Canada Ltd.

05228 \$124,105.02 3.90 \$1,422.50 Pending \$1,422.50 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 64 of 373

-24-05229 \$148,425.70 3.40 \$1,669.00 Pending/Settlement

-24-05233 \$250,000.00 .80 \$370.00 Pending/In Mediation \$727.00

-24-05238 \$92,260,305.88 3.00 \$1,222.50 Pending

24-05243 \$17,079,662.38 .30 \$127.50 Pending \$127.50

24-05245 \$3,957,808.00 1.10 \$422.50 Pending \$613.00 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 65 of 373

-24-05246 \$523,396.35 1.50 \$796.00 Pending \$1,398.00

-24-05247 \$263,890.70 .80 \$270.00 Pending \$679.00

05248 \$190,000.00 .40 \$170.00 Pending \$170.00

-24-05251 \$3,000,000.00 .20 \$99.00 Pending \$99.00

24-05253 \$125,825.14 .10 \$42.50 Pending \$42.50

05258 \$1,010,129.68 .60 \$297.00 Pending \$297.00 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 66 of 373

05263 \$10,000,000.00 .20 \$85.00 Pending \$42.50

24-05264 \$1,850,000.00 .10 \$42.50 Pending \$42.50

05266 \$1,020,000.00 .80 \$295.00 Pending \$295.00

05269 \$270,000.00 2.10 \$936.50 Pending \$769.00

05271 \$118,192.35 .10 \$42.50 Pending \$42.50

Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 67 of 373

24-05315 \$390,440.22 4.50 \$1,734.50 Pending \$3,767.50

USA, Inc.

05293 \$547,076.34 .30 \$127.50 Pending \$127.50

24-05294 \$462,798.21 .20 \$85.00 Pending \$85.00

-24-05295 \$5,000,00.00 .80 \$250.00 Pending \$250.00

Shield Ltd. 24-05296 \$274,571.43 .20 \$85.00 Pending \$85.00

05297 \$252,808.78 .80 \$250.00 Pending \$250.00 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 68 of 373

24-05298 \$304,962.41 2.90 \$1,232.50 Pending \$1,232.50

24-05299 \$246,727.63 1.20 \$448.00 Pending \$42.50

24-05301 \$340,040.00 1.60 \$646.00 Pending \$42.50

05302 \$500,000.00 .70 \$207.50 Pending \$85.00

05303 \$376,250.45 .50 \$167.50 Pending \$167.50 L946 Teneo Ltd.

05304 \$1,001,805.95 1.50 \$592.50 Pending \$592.50 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 69 of 373

05305 \$305,191,55 .30 \$127.50 Pending \$127.50

24-05306 \$472,396.37 .50 \$167.50 Pending \$167.50

-24-05307 \$260,253.12 .50 \$167.50 Pending \$167.50

24-05308 \$255,000.00 .50 \$212.50 Pending \$212.50

-24-05309 \$1,617,778.50 .10 \$42.50 Pending \$42.50

05310 \$500,000.00 .10 \$42.50 Pending \$42.50 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 70 of 373

05313 \$653,837.93 45.1 \$20,906.00 Pending

24-05279 \$676,250.00 .40 \$198.00 Pending \$45.00

24-05286 \$5,560,056.39 .90 \$382.50 Pending \$382.50

24-05280 \$1,363,599.25 4.70 \$2,240.50 Pending \$2,240.50

24-05287 \$360,791.37 .30 \$127.50 Pending \$127.50

24-05288 \$329,764.36 .20 \$85.00 Pending \$85.00 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 71 of 373

-24-05289 \$310,664.91 .20 \$85.00 Pending \$85.00

-24-05290 \$3,153,823.50 .10 \$42.50 Pending \$42.50

L963 Epic IT Ltd. -24-05292 \$907,530.79 .20 \$85.00 Pending \$85.00

24-05271 \$4,719,050.80 .4 \$170.00 Pending \$290.00

05316 \$589,453.99 1.20 \$417.00 Pending \$417.00

05317 \$340,193.79 1.3 \$407.50 Pending \$407.50

Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 1 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 73 of

P B110 A101 220.00 0.20 44.00 Confer with Attorney Skalka regarding necessary revisions to the monthly operating report and attachment. Revise same.

P B110 A105 425.00 0.20 85.00 Bankruptcy Representation

Despins, Ch 11 Trustee/Luc A.

P B110 A101 200.00 0.20 40.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B110 A105 425.00 0.20 85.00 Correspond with T. Dembowski regarding targets

Despins, Ch 11 Trustee/Luc A.

P B110 A101 220.00 3.00 660.00 Continue to prepare conflict checks in connection with adversary proceedings. Despins, Ch 11 Trustee/Luc A.

P B110 A105 495.00 0.30 148.50 Correspond and confer with D. Skalka regarding monthly operation reports (0.2), confer with D.

Despins, Ch 11 Trustee/Luc A.

P B110 A101 220.00 0.30 66.00 Prepare draft monthly operating report for August 2024.

B110 A111 550.00 0.40 220.00 Draft memorandum to attorney T. Sadler

statement (.2); drat memorandum to attorney Millman regading Sherry Netherland deposit

P B110 A101 200.00 0.20 40.00 Draft and send memorandum to T. Jones and D. Skalka regarding the status of the monthly

B110 A111 550.00 0.50 275.00 Bankruptcy Representation Review operating report and draft memorandum to director with report for review (.4); draft memorandum to T. Jones regarding filing of

P B110 A101 220.00 0.40 88.00 Review draft Kwok monthly operating report for August 2024. Prepare draft monthly operating report and attachments to the August 2024 MOR.

P B110 A101 220.00 0.60 132.00 Bankruptcy Representation Review bank statement and security deposit details. Prepare draft monthly operating report and attachments for August 2024.

B110 A111 550.00 0.80 440.00 Review and revise September operating report (.5); Draft memorandum to client with report for

P B110 A101 200.00 0.60 120.00 Draft appearances for Attorneys Despins, Barron, Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 2 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 74 of

220.00 1.00 220.00 Bassett, and Maza for district court proceedings

appearances to Attorney Linsey for review (.2) Despins, Ch 11 Trustee/Luc A.

preparation of annual financial statement. Review monthly operating reports filed in 2023. Prepare draft financial statement. Confer with Attorney Skalka regarding necessary revisions to include liabilities. Revise same.

550.00 0.40 220.00 Bankruptcy Representation Review and revise 2023 annual report for BVI

annual report Draft memorandum to client with 2023 BVI

Review updated conflict searches regarding

Despins, Ch 11 Trustee/Luc A.

550.00 0.40 220.00 Ho Wan Kwok, Debtor Review operating report and draft memorandum

550.00 0.50 275.00 Review and revise operating report (.3); draft

495.00 0.20 99.00 Attention to motion to extend time to remove civil actions and correspond with A. Bongartz

Despins, Ch 11 Trustee/Luc A.

550.00 0.30 165.00 Draft memorandum to attorneys Sadler and Mllmand regarding account information for

review(.2) Review operating report (.30); draft memorandum to attonrey Barron with report for

550.00 0.40 220.00 Review operating report (.2); draft memorandum

425.00 0.10 42.50 Correspond with P. Linsey regarding extension of

Despins, Ch 11 Trustee/Luc A.

495.00 0.10 49.50 Correspond with K. Mitchell and D. Mohamed regarding extension of deadline to remove civil

Despins, Ch 11 Trustee/Luc A.

200.00 0.80 160.00 Review main case CM/ECF notification list and

Linsey and Attorney Sutton regarding amount of Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 3 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 75 of

Phase ID B110 Case Administration individuals notified of filings Despins, Ch 11 Trustee/Luc A.

B110 A101 220.00 2.00 440.00 Prepare draft supplemental declaration (1.4);

Despins, Ch 11 Trustee/Luc A.

B110 A111 550.00 0.20 110.00 Draft memo to attorney Sadler regarding bank

B110 A111 550.00 0.20 110.00 Bankruptcy Representation Draft memorandum to attonrey Sadler regarding

B110 A101 220.00 0.30 66.00 Prepare draft monthly operating report for November 2024.

B110 A101 220.00 1.00 220.00 Review documents. Prepare draft monthly

B110 A111 550.00 0.50 275.00 Review operating report; draft memorandum to

B110 A111 550.00 0.40 220.00 Review November operating report; draft memorandum to client and attorney Barron with

B110 A101 220.00 0.20 44.00 Review correspondence from Attorney Skalka. Prepare attachments to the monthly operating report. Attend to filing the November 2024 monthly operating report.

B110 A101 220.00 0.20 44.00 Bankruptcy Representation Finalize the attachments to the November 2024 monthly operating report. Attend to filing of the November 2024 monthly operating report.

B110 A111 550.00 0.30 165.00 Draft memorandum to Director and T. Jones

B110 A111 550.00 0.20 110.00 Draft memorandum to attorney Barron and T.

Total for Phase ID B110 Billable 19.30 6,853.50 Case Administration

Phase ID B120 Asset Analysis and Recovery

B120 A111 550.00 1.30 715.00 Review foreign defendant cases and assign

memorandum to S. Pierce with case assignment

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review correspondence from Metro Bank (.1),

Despins, Ch 11 Trustee/Luc A. Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 4 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 76 of

Phase ID B120 Asset Analysis and Recovery

Correspond with D. Skalka regarding ability to

Despins, Ch 11 Trustee/Luc A.

attention to discovery/subpoena production

Despins, Ch 11 Trustee/Luc A.

correspond with E. Cohen regarding service

Despins, Ch 11 Trustee/Luc A.

Review ECF filings and update master case

Despins, Ch 11 Trustee/Luc A.

382.50 Analyze document production status,

Despins, Ch 11 Trustee/Luc A.

127.50 Review request from Old National Bank, prepare

Despins, Ch 11 Trustee/Luc A.

595.00 attention to outstanding requests from Kroll for

Despins, Ch 11 Trustee/Luc A.

85.00 Correspond with IDB regarding July 12

Despins, Ch 11 Trustee/Luc A.

1,008.00 Meet-and-confer regarding motion to preserve (0.9); preparation for meet-and-confer regarding motion to preserve, including review of SCA (1.2). Despins, Ch 11 Trustee/Luc A.

Draft memorandum to P. Linsey regarding status

Despins, Ch 11 Trustee/Luc A.

255.00 Research citibank documents produced in November/December pursuant Kroll's request in directory and Relativity (.4), correspond with ULX

Despins, Ch 11 Trustee/Luc A.

85.00 follow up with Comerica Bank regarding

Despins, Ch 11 Trustee/Luc A.

680.00 compile and analyze productions related to subpoena and data provided by Kroll (1.1), cont draft memorandum to P. Linsey regarding same

Despins, Ch 11 Trustee/Luc A.

85.00 Correspond with China CITIC regarding meet and confer related to subpoena non-compliance Despins, Ch 11 Trustee/Luc A.

85.00 Review request from Metro Credit Union regarding 2004 discovery targets, reply to same

Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 5 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 77 of

Phase ID B120 Asset Analysis and Recovery Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with ULX regarding Citibank upload Despins, Ch 11 Trustee/Luc A.

P B120 A101 495.00 5.80 2,871.00 Prepare for NPM update meeting and draft

regarding various litigation/avoidance/discovery projects (1.5), correspond with N. Bassett regarding Bernardo Enriquez discovery issues (0.2), correspond with E. McDaniels regarding Bernardo Enriquez Rule 2004 discovery issues and avoidance issues (0.2), confer with D. Carnelli regarding Google response to Court's order on accounts that are property of the estate (0.2),

S. Moore regarding developments re: Cirrus jet and correspond with S. Moore regarding same

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.20 85.00 Ho Wan Kwok, Debtor Review status of Bank of China production,

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Review correspondence from China CITIC

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 attention to response from IDB Bank regarding status of supplemental production, respond to

Despins, Ch 11 Trustee/Luc A.

P B120 A108 480.00 0.70 336.00 Multiple correspondence with representative regarding motion to preserve and court order to preserve (sealed ECF 3444). Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 correspond with Bank of China regarding status

Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.30 60.00 E-mail with Attorney Mitchell regarding check to Comerica Bank for document production and follow up with A. DiDomenico regarding same (.2); e-mail to Attorney Mitchell with updated check information and mail check to client (.1) Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 2.00 850.00 Review response from Old National Bank regarding no records (.2), research specific accounts/entities including identifiers for Golden Eagle and River Valley (1.6), respond and provide

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor Further correspondence with Old National Bank

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Phase ID B120 Asset Analysis and Recovery

B120 A104 425.00 0.20 85.00 regarding EIN and account numbers Despins, Ch 11 Trustee/Luc A.

outstanding invoice, correspond with K.

B120 A104 425.00 0.30 127.50 Ahumada regarding status of outstanding check Despins, Ch 11 Trustee/Luc A.

regarding status of last check (.1), obtaining a new check and provided copy of invoice (.1),

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with Comerica contact to relay information regarding issuance of new check Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Attention to correspondence from E. Cohan regarding Vantage West Credit Union service, research registered agent address, reply to E. Cohan regarding same. Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.60 255.00 Review mobile data uploads on Relativity Despins, Ch 11 Trustee/Luc A.

B120 A107 495.00 1.30 643.50 Correspond with N. Bassett and D. Barron regarding Aviation Trust Company and Cirrus jet

investigations (0.8), attention to Greenwich mail

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 1.40 595.00 Review analysis from Kroll regarding documents needed from 20 banks/financial institutions (.6), draft memorandum regarding plan to obtain

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with Old National Bank regarding

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with Kroll regarding Bank of the

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 review response from China CITIC's counsel

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with Kroll and counsel regarding

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 1.50 637.50 Correspond with Comerica regarding supplemental production (.2), review production (1.1), correspond with ULX regarding upload of

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.50 212.50 Confer with counsel to China CITIC regarding Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 7 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 79 of

Phase ID B120 Asset Analysis and Recovery

B120 A108 425.00 0.20 85.00 subpoena compliance Despins, Ch 11 Trustee/Luc A.

regarding specific known accounts, provide

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.40 170.00 Ho Wan Kwok, Debtor Review data provided by Kroll related to China CITIC accounts, prepare for meet and confer with

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor Correspond with P. Linsey regarding G Service

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.80 340.00 Ho Wan Kwok, Debtor Revise materials related to subpoena status,

Despins, Ch 11 Trustee/Luc A.

B120 A103 495.00 1.20 594.00 Despins, Ch 11 Trustee/Luc A.

B120 A103 495.00 0.70 346.50 Ho Wan Kwok, Debtor

B120 A101 200.00 0.40 80.00 Despins, Ch 11 Trustee/Luc A.

Review e-mail from Attorney Mitchell and mark

documents (.3); send to Attorney Mitchell for

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor Review correspondence from China CITIC and

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 attention to voicemail from Hughes Federal

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.40 170.00 confer with counsel to Rockland Trust regarding

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.50 212.50 Review request from Rockland Trust regarding multiple positive hits and additional information required, research the PII and reply to same Despins, Ch 11 Trustee/Luc A. Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 8 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 80 of

Phase ID B120 Asset Analysis and Recovery

A103 425.00 1.30 552.50 Review updated analysis of citibank accounts from Kroll for follow up, revise subpoena and

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.70 297.50 Review updated and new requests analysis from Kroll regarding Citizens account, revise subpoena

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.40 170.00 Review Kroll analysis of updated requests and new accounts at Wells Fargo, revise subpoena Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.10 42.50 correspond with P. Linsey regarding revised

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.10 42.50 Confer with P. Linsey regarding WF subpoena Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.20 85.00 Review request from E. Sutton regarding IDB

Despins, Ch 11 Trustee/Luc A.

A111 550.00 0.70 385.00 Attend conference call with client , attorney Linsey , attorney Bassett and attorney Barron on

Despins, Ch 11 Trustee/Luc A.

draft motion regarding Aviation Trust Company and correspond with trustee and K. Mitchell

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.10 42.50 Correspond with P. Linsey regarding Aviation

Despins, Ch 11 Trustee/Luc A.

A108 480.00 0.20 96.00 Correspond with Google regarding preservation of accounts. Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.20 85.00 correspond with IDB bank about supplemental

Despins, Ch 11 Trustee/Luc A.

A103 425.00 0.30 127.50 Further revise WF subpoena and RFP, correspond with counsel for WF regarding service of same Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.20 85.00 Review response from WF that will check with client regarding service, reply with additional

Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 9 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 81 of

Phase ID B120 Asset Analysis and Recovery

P B120 A104 425.00 1.50 637.50 Despins, Ch 11 Trustee/Luc A.

correspond with ULX regarding upload of same

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.60 255.00 Ho Wan Kwok, Debtor Revise materials related to 2004 discovery targets

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor attention to correspondence from Citizens bank

Despins, Ch 11 Trustee/Luc A.

P B120 A109 495.00 1.90 940.50 Ho Wan Kwok, Debtor Attend Zoom hearing regarding Ace Decade and omnibus alter ego adversary proceedings and

conference (0.4), confer with trustee regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A105 480.00 1.00 480.00 Ho Wan Kwok, Debtor Multiple correspondence with Attorney Linsey regarding Google preservation (0.3); review docket entry 3517 regarding appeal in USCA2d

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.20 85.00 Ho Wan Kwok, Debtor Review request for extension on motion to compel from DBS, correspond with P. Linsey

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 2.50 1,062.50 Ho Wan Kwok, Debtor

memorandum to P. Linsey regarding transactions Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.20 85.00 rec'v and review correspondence from Rockland Trust regarding found accounts and projected

Despins, Ch 11 Trustee/Luc A.

P B120 A105 480.00 0.80 384.00 Call with P. Linsey regarding potential property rented by party; investigate property and ownership and address options for further discovery (.5); calls with realtors regarding the

Despins, Ch 11 Trustee/Luc A.

P B120 A104 495.00 1.20 594.00 Attention to revised proposed orders from Tuesday hearing and correspond with trustee regarding same (0.2), correspond with courtroom deputy to submit revised orders (0.2), draft

Aviation Trust Company and Cirrus jet (0.8) Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.40 220.00 Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Receive and review record related to Walden Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 10 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 82 of

Phase ID B120 Asset Analysis and Recovery Macht transfer from IDB, correspond with IDB

Despins, Ch 11 Trustee/Luc A.

B120 A106 425.00 0.10 42.50 Correspond with ES regarding IDB transfer

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 1.80 765.00 Finalize memorandum regarding Lake City Bank production, correspond with P. Linsey regarding

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.80 340.00 Ho Wan Kwok, Debtor Prepare analysis of Lake City Bank transfers,

Despins, Ch 11 Trustee/Luc A.

B120 A106 425.00 0.10 42.50 Confer with ES regarding consent to reference confidential documents in foreign jurisdiction Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.30 127.50 Compose request to UBS regarding consent to

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.20 85.00 Compose request to standard chartered regarding consent to use information contained

Despins, Ch 11 Trustee/Luc A.

B120 A106 425.00 0.10 42.50 Ho Wan Kwok, Debtor Correspond with ES and P. Linsey regarding

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.30 127.50 Draft motion to adjourn hearing on motion to compel DBS, correspond with counsel for DBS

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.20 85.00 compose and send request to HSBC regarding

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.20 85.00 Compose and send request to W&C regarding consent to use information contained in their

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.40 170.00 Correspond and provide copies of relevant documents to four banks related to injunction and confidentiality agreements. Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Confer with P. Linsey regarding confidentiality designations. Despins, Ch 11 Trustee/Luc A.

B120 A106 495.00 1.50 742.50 Correspond with trustee and A. de Quincey regarding Cirrus jet issues and review and analyze advice from UK counsel (0.2), review and analyze K. Mitchell analysis regarding Lake City Bank and correspond with K. Mitchell regarding

Phase ID B120 Asset Analysis and Recovery same/next steps (0.3), review and analyze S. Elam email regarding involvement of JNFX (0.4),

related production (0.4), correspond with K. Mitchell and Kroll regarding JNFX and GFC

Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.20 85.00 Correspond with Kroll and P. Linsey regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A105 480.00 0.30 144.00 Multiple correspondence with Attorney Mitchell regarding appeal in USCA2d 24-1271. Despins, Ch 11 Trustee/Luc A.

P B120 A102 425.00 3.10 1,317.50 Research Relativity for GFC Global and Gerald/Gerry McClement (2.8), memorandum to

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.30 127.50 Review correspondence from HSBC regarding subpoena compliance, correspond with E. Cohan

Despins, Ch 11 Trustee/Luc A.

P B120 A102 425.00 2.00 850.00 Research Mountains of Spices and Rainbow Gifts on Relativity related to WF updated subpoena (.9), correspond with counsel for WF regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.60 255.00 Receive and review supplemental records from Israel Discount Bank, correspond with ULX

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.40 170.00 Rec'v inquiry from UBS regarding disclosure of records in foreign proceeding (.1), correspond

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.10 42.50 Correspond with E. Cohan regarding HSBC

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.20 85.00 Review correspondence from UBS regarding consent to use information in foreign filing, draft

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with counsel to HSBC regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.30 127.50 Review response from IDB regarding bank

Despins, Ch 11 Trustee/Luc A.

(.3);

.2);

Phase ID B120 Asset Analysis and Recovery (.4); draft memorandum to attorney Smeriglio

A107 495.00 0.70 346.50 regarding status of action (.1) Despins, Ch 11 Trustee/Luc A.

Correspond and confer with trustee and N. Bassett regarding call with avoidance defendants re:

and trustee regarding Cirrus jet in UK (0.3),

A111 550.00 0.70 385.00 correspond with A. de Quincey regarding Aviation Trust Company and Cirrus issues (0.2) Despins, Ch 11 Trustee/Luc A.

(.4);

Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.20 85.00 Review response from Williams & Connolly regarding consent to use information in foreign filing, correspond with E Sutton regarding same Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.30 127.50 Draft and send response to HSBC regarding use

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.20 85.00 Review China CITIC's R&Os to subpoena Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.70 297.50 Analyze the production from IDB related to the

correspond with L. Song regarding same (.1),

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.30 127.50 attention to subpoena response from Hughes Federal Credit Union (.2), draft memorandum to

Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.10 42.50 Correspond with ULX regarding Rockland Trust

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.20 85.00 Review response from Vantage West regarding out of state subpoena, correspond with P. Linsey

Despins, Ch 11 Trustee/Luc A.

A105 495.00 0.10 49.50 Correspond with K. Mitchell regarding Hughes

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.10 42.50 Correspond with P. Linsey regarding Hughes Fed.

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.20 85.00 Correspond and confer with P. Linsey regarding

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Phase ID B120 Asset Analysis and Recovery

P B120 A108 425.00 0.20 85.00 Despins, Ch 11 Trustee/Luc A.

review further correspondence from China CITIC, reply and provide prior motions to compel other

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.30 127.50 Ho Wan Kwok, Debtor Follow up with HSBC and Standard Chartered regarding use of information in foreign filing (.2), memorandum to E. Sutton regarding same (.1) Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.40 170.00 Ho Wan Kwok, Debtor review 7th motion to adjourn DBS MTC (.3), correspond with K. Ahumada regarding filing of

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.20 40.00 Ho Wan Kwok, Debtor E-mail with Attorney Mitchell regarding filing of motion to adjourn hearing and file same (.1);

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.20 85.00 Ho Wan Kwok, Debtor attention to correspondence from Rockland Trust regarding outstanding subpoena production,

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor Review notes from P. Linsey regarding Hughes Federal Credit Union, correspond with contact

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.30 127.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.90 382.50 Review criminal trial exhibits via Relativity Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with Vantage West bank regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 correspond with Vantage West regarding meet and confer schedule, attention to zoom invite Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.90 382.50 review REM supplemental production Despins, Ch 11 Trustee/Luc A.

P B120 A106 495.00 0.50 247.50 Correspond with trustee regarding update meeting and task list (0.2), review and analyze revised task list and correspond with PHC1

Despins, Ch 11 Trustee/Luc A. Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 14 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 86 of

Phase ID B120 Asset Analysis and Recovery Ho Wan Kwok, Debtor

B120 A111 550.00 0.60 330.00 (.2); (.2);

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.40 220.00 Telephone attorney Heath regarding utility accounts fro greenwich property and payment of

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Confer with Metro Credit Union regarding

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.40 170.00 Confer with Hughes Federal Credit Union regarding subpoena issued in 16th 2004 motion Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.50 212.50 Research Hamilton entities on Relativity for

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.40 170.00 Draft memorandum in response to citibank's

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Review information from Kroll regarding Metro Credit Union, request additional information

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.50 212.50 Confer with Citibank regarding updated

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 attention to information from Kroll regarding Metro Credit Union accounts, correspond with

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Attention to question from HSBC regarding injunction, correspond with E. Sutton regarding

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Review instruction from D. Barron regarding foreign proceeding and inquiries by HSBC and Standard Chartered, correspond with HSBC and

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 1.20 510.00 Review initial production from First Fidelity Bank (1.1), correspond with ULX regarding upload of

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.40 170.00 Confer with United Bank regarding subpoena

Despins, Ch 11 Trustee/Luc A.

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Phase ID B120 Asset Analysis and Recovery

P B120 A108 425.00 0.20 85.00 attention to information from E. Cohan regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.60 255.00 Confer with United Bank regarding subpoena production and related issues (.4), correspond

Despins, Ch 11 Trustee/Luc A.

P B120 A106 495.00 2.00 990.00 Ho Wan Kwok, Debtor Confer with trustee regarding Aviation Trust Company (0.1), confer with S. Ingram (Aviation Trust Company) regarding trust agreement (0.3),

regarding Cirrus jet issues (0.6), correspond with N. Bassett and trustee regarding strategy and next steps for Cirrus jet (0.3), correspond with S. Ingram regarding update on past due Cirrus invoices and confer with trustee regarding same

Despins, Ch 11 Trustee/Luc A.

P B120 A105 480.00 0.20 96.00 Ho Wan Kwok, Debtor Correspond with Attorney Linsey regarding appeal in USCA2d 24-1271. Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.20 110.00 Ho Wan Kwok, Debtor Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.40 170.00 Review inquiry by Midfirst Bank regarding subpoena, research additional information for

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with Midfirst Bank regarding status

Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.10 20.00 Attention to e-mail from Attorney Linsey; calendar date to follow up with Google re document preservation and send to Attorneys

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Further correspondence with ULX regarding First

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.10 42.50 Correspond with UBS regarding consent to use information in complaint to be filed in adversary

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with W&C regarding consent to use their data in complaint to be filed in the Bouillor Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.40 170.00 Meet and confer with Vantage West Bank

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Phase ID B120 Asset Analysis and Recovery

B120 A108 425.00 0.20 85.00 Despins, Ch 11 Trustee/Luc A.

Correspond with Kroll regarding Vantage West

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 0.40 80.00 Ho Wan Kwok, Debtor File emergency motion and related documents

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 1.20 510.00 Research additional information related to Wells Fargo new targets (1), correspond with WF to

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.60 255.00 Review 2004 subpoena PII chart with information

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Review inquiry from DBS regarding foreign actions (.1), inquire from E. Sutton regarding

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Draft and review correspondence to Standard Chartered regarding injunction (.2), correspond with E. Sutton regarding scope of disclosure (.1) Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.60 255.00 review information provided by Kroll regarding VOG accounts at Vantage West (.2), search Relativity for additional identifiers (.3), correspond with Vantage West to provide same

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Review motion to quash filed by River Valley and Golden Ventures (.2), correspond with P. Linsey

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 1.40 595.00 Research additional PII for specific targets requested by United Bank (1.1), update PII chart (.3) correspond with Bank regarding same (.1) Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Confer with P. Linsey regarding motion to quash

Despins, Ch 11 Trustee/Luc A.

B120 A103 480.00 4.40 2,112.00 Revise/update memorandum on SCA and non-content information (2.5); correspond with Attorney Linsey regarding the same (0.2); confer with Attorney Linsey on next steps regarding Microsoft and Google Accounts (0.9); multiple

regarding meet-and-confer (0.4); review notice filed regarding unsealed papers for motion to preserve (0.4). Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 attention to inquiry from Standard Chartered regarding use of underlying information from production and filing of action, respond to same Despins, Ch 11 Trustee/Luc A.

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Phase ID B120 Asset Analysis and Recovery Ho Wan Kwok, Debtor

P B120 A103 495.00 3.40 1,683.00 Draft notice of Microsoft filings and correspond with K. Ahumada and D. Carnelli regarding same (0.6), confer with D. Carnelli regarding next steps to obtain email domains (0.5), correspond with D. Barron regarding CBS/Golden Spring production and review production (0.3), confer with D. Barron regarding various parties confidentiality stipulations (0.4), review and analyze Hao/River Valley Ops/Golden Eagle motion to quash (0.4), memorandum to D. Barron and Kroll regarding same (0.2), confer with K. Mitchell regarding motion to quash and other Rule 2004 discovery compliance issues (0.2), correspond with team regarding filing conventions for alter egos filings

regarding Cirrus jet/invoices and correspond with trustee regarding same (0.3), research movement of Cirrus jet and correspond with D.

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.30 127.50 Ho Wan Kwok, Debtor

regarding consent of information use (.1), reply to same (.1), correspond with E. Sutton to relay

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.40 170.00 Ho Wan Kwok, Debtor Review analysis by Kroll related to River Valley and Golden Eagle Ventures, correspond with P.

P B120 A105 425.00 0.20 85.00 Despins, Ch 11 Trustee/Luc A.

confer and corresond with P. Linsey regarding River Valley Operations/Golden Eagle Ventures Despins, Ch 11 Trustee/Luc A.

P B120 A104 480.00 5.40 2,592.00 Ho Wan Kwok, Debtor Conduct initial review/analysis of appellants' brief in USCA2d No. 24-1271 (1.1); conduct initial review/analysis of joint appendix in USCA2d No. 24-1271 (2.3); begin drafting outline for appellee's responsive brief in USCA2d No. 24-1271 (2.0). Despins, Ch 11 Trustee/Luc A.

P B120 A106 425.00 0.60 255.00 Attend Kroll/PH meeting regarding recent bank

Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor Confer with P. Linsey regarding 17th Rule 2004

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.80 340.00 Ho Wan Kwok, Debtor Analyze MidFirst Bank production, correspond

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.80 340.00 Analyze information regarding additional BoA targets/accounts, draft subpoena and RFP to

Despins, Ch 11 Trustee/Luc A.

P B120 A102 425.00 1.00 425.00 Ho Wan Kwok, Debtor Research new targets on Relativity for subpoenas Despins, Ch 11 Trustee/Luc A.

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Phase ID B120 Asset Analysis and Recovery

P B120 A108 425.00 0.10 42.50 Correspond with BoA regarding acceptance of

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.80 340.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with MidFirst Bank regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.20 85.00 Ho Wan Kwok, Debtor

correspondence related to upcoming production Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.40 170.00 attention to Kroll breakdown of additional banks and 2004 targets (.2), correspond with P. Linsey

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.30 127.50 Ho Wan Kwok, Debtor Review comments from N. Bassett (.1), finalize Podhaskie subpoena (.1), and correspond with P.

Despins, Ch 11 Trustee/Luc A.

P B120 A104 495.00 2.60 1,287.00 Ho Wan Kwok, Debtor

correspondence regarding Golden Eagle (1.2), confer with A. Lomas regarding Golden Eagle (0.2), attend Kroll update meeting (0.6), correspond and confer with K. Mitchell regarding Golden Eagle (0.2), correspond and confer with K. Mitchell regarding 17th Rule 2004 motion (0.3), correspond with R. Fingold regarding Golden

Despins, Ch 11 Trustee/Luc A.

P B120 A108 480.00 0.20 96.00 Multiple correspondence with Attorney

Microsoft Domains. Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.30 127.50 attention to correspondence from Standard Chartered regarding use of information in foreign proceeding (.2), respond to inquiries (.1) Despins, Ch 11 Trustee/Luc A.

P B120 A106 425.00 0.20 85.00 Correspond with E. Sutton related to status of consent from banks to use information in foreign proceedings. Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.50 100.00 Service of Rule 9019 filings onto manual service

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.30 127.50 Finalize BoA subpoena, draft outline of requests and correspond with counsel regarding same Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 1.30 552.50 Review production from Metro Credit Union (1.2), correspond with ULX regarding same (.1) Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 19 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 91 of

Phase ID B120 Asset Analysis and Recovery

B120 A104 425.00 0.30 127.50 Despins, Ch 11 Trustee/Luc A.

Multiple correspondence with Metro Credit Union regarding production and affidavit of

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 0.20 40.00 Ho Wan Kwok, Debtor Telephone call with Attorney Linsey regarding upcoming deadlines and case administration Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.30 127.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.80 340.00 Ho Wan Kwok, Debtor Review bank of america productions related to

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A101 495.00 5.30 2,623.50 Ho Wan Kwok, Debtor Prepare for global task list/litigation update call with trustee (0.8), draft agenda for global task list/litigation update call with trustee (0.7),

regarding draft agenda (0.1), attend part 1 of global task list/litigation update call with trustee (1.4), correspond with D. Skalka regarding ownership of motorcycles (0.2), correspond with

issues list (0.2), correspond with K. Mitchell and N. Bassett regarding Daniel Podhaskie subpoena

(0.1), attend part 2 of global task list/litigation

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.10 42.50 Ho Wan Kwok, Debtor Correspond with P. Linsey regarding Podhaskie

Despins, Ch 11 Trustee/Luc A.

B120 A103 480.00 1.50 720.00 Continue outlining/revise outline regarding points and authorities for appellee brief in USCA2d 24-1271. Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.20 85.00 Revise Podhaskie supboena, correspond with P.

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 1.20 510.00 Review analysis from Kroll regarding additional banks/entities, research banks, and draft 17th

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with Kroll regarding locations of

Despins, Ch 11 Trustee/Luc A.

B120 A108 480.00 3.90 1,872.00 Meet-and-confer with Microsoft's counsel and Attorney Linsey re: Microsoft domains (re: ECF

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NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery 3444) (0.6); prepare for meet-and-confer with Microsoft's counsel re: Microsoft domains (1.3); correspond with Attorney Linsey regarding SCA authority for non-content information (0.2); conduct legal research for USCA2d 24-1271 regarding scope of appeal to circuit court from decision of district court (on appeal from BK court) (1.8). Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.30 127.50 Review analysis from A. Lomas regarding Axos

Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.10 42.50 Ho Wan Kwok, Debtor Correspond with contact at Axos regarding

subpoena via e-mail. Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.90 382.50 Ho Wan Kwok, Debtor review analysis from A. Lomas regarding Barclays and newly identified accounts, draft amended

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor correspond with P. Linsey regarding motion to

Despins, Ch 11 Trustee/Luc A.

A101 425.00 0.50 212.50 Prepare for meet and confer with counsel for

Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.30 127.50 Meet & confer with counsel to Golden Eagle, River Valley, and Yumei Hao's motion to quash

Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.30 127.50 attention to response and inquiry from Axos Bank, compile data and reply to contact with

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.30 127.50 Review exhibits related to Yumei Hao from criminal trial and HCHK a.p. Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.20 85.00 review reply from Axos Bank regarding acceptance of updated subpoena, reply to same Despins, Ch 11 Trustee/Luc A.

A101 495.00 4.60 2,277.00 Prepare for conference with Microsoft counsel regarding administrator of accounts (0.4), confer with Microsoft counsel and D. Carnelli regarding administration of accounts and SCA issues (0.5), correspond with D. Carnelli in follow-up to same (0.2), prepare for conference with counsel for Golden Eagle/River Valley/Yumei Hao regarding motion to quash (0.6), confer with K. Mitchell and PHC1 regarding motion to quash (0.2), confer with R. Fingold regarding motion to quash (0.3), correspond with PHC1 and N. Biale regarding Sian Jing (0.3), prepare for NPM weekly update meeting and draft agenda (0.6), attend NPM Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 21 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 93 of

Date: 02/24/2025 Doc 4159 Filed 02/24/25 373 Entered 02/24/25 23:41:51

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

Correspond with trustee regarding results of

correspond with N. Bassett regarding D. Podhaskie subpoena (0.2), attention to D. Podhaskie subpoena and correspond with D. Podhaskie and K. Mitchell regarding same (0.3),

(0.1), correspond with K.

defendants assignments list with changes and confer with D. Skalka regarding same (0.2) Despins, Ch 11 Trustee/Luc A.

Attend conference call with client , attorney Linsey and attorney Bassett regarding discovery

Despins, Ch 11 Trustee/Luc A.

attention to comments from Wells Fargo on missing target information (.2), research relativity for additional information (1.1), provide findings

Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

Correspond with A. Lomas regarding 17th 2004

Despins, Ch 11 Trustee/Luc A.

Correspond with Santander contact regarding

Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

Correspond with A. Lomas regarding 17th 2004

Despins, Ch 11 Trustee/Luc A.

Correspond with Santander contact regarding ability to accept service of updated subpoena via

Despins, Ch 11 Trustee/Luc A.

Revise 2004 subpoena tracker with updated

Despins, Ch 11 Trustee/Luc A.

missing information on new targets, provide

Despins, Ch 11 Trustee/Luc A.

Correspond with Microsoft's counsel regarding Microsoft Domains (with outline to decisional authority regarding non-content information) (0.5); conduct supplemental legal research for decision authorities addressing permissible scope of non-content disclosures under SCA (2.7); draft/revise appellee's brief in USCA2d

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Phase ID B120 Asset Analysis and Recovery 24-1271 (2.8). Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Confer with WF regarding updated supboena Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.40 170.00 Confer with Rockland Trust regarding subpoena

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor rec'v and review follow up contact from Standard Chartered Bank, correspond with E. Sutton

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.10 42.50 Follow up with HSBC regarding use of information derived from confidential production

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.50 212.50 Analyze initial United Bank production of

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 0.10 20.00 Draft and file transcript request in main case Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Serve updated Axos subpoena pursuant to their

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.40 170.00 Research additional identifiers for Fiesta Investment companies for subpoena compliance Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.70 297.50 draft updated Santander Bank subpoena, arrange

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 attention to request for information regarding new targets from Axos bank, reply to same Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Review prior information regarding Bank of

compliance with Subpoena or meet and confer,

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.40 170.00 Attention to prior responses from Amex, correspond with contact to follow up on GFNY accounts. Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.10 42.50 Correspond with ULX regarding United Bank

Despins, Ch 11 Trustee/Luc A.

B120 A106 425.00 0.20 85.00 Ho Wan Kwok, Debtor attention to correspondence from E. Sutton regarding SCB transactions in Cyprus action Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.10 42.50 Correspond with P. Linsey regarding foreign

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Phase ID B120 Asset Analysis and Recovery

A104 425.00 0.20 85.00 Despins, Ch 11 Trustee/Luc A.

Review all information/correspondence related to use of confidential information in foreign

Despins, Ch 11 Trustee/Luc A.

A101 495.00 1.00 495.00 Ho Wan Kwok, Debtor Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.40 170.00 Ho Wan Kwok, Debtor confer with P. Linsey regarding foreign injunction Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.30 127.50 Ho Wan Kwok, Debtor Review letter from Vantage West regarding inability to locate accounts, correspond with contact regarding same, relay information to

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.20 85.00 Ho Wan Kwok, Debtor attention to response from Amex regarding

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.20 85.00 Review analysis from A. Lomas regarding PNC

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor attn to correspondence from P. Linsey regarding service of D. Podhaskie subpoena for testimony, reach out to Deposit. Carnelli regarding witness

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.20 85.00 Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.30 127.50 Ho Wan Kwok, Debtor

regarding serving of Podhaskie subpoena and

Despins, Ch 11 Trustee/Luc A.

A101 200.00 0.10 20.00 Draft witness fees check request for Podhaskie

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor Review response from D. Carnelli regarding fees for subpoena witnesses, correspond with K.

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.20 85.00 attn to request from Santander regarding time

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.30 127.50 Review prior PNC production on relativity,

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.30 127.50 Review analysis from A. Lomas on M&T and Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 24 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 96 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

425.00 0.30 127.50 Ho Wan Kwok, Debtor Review material provided from Kroll regarding other new entities to include in the 17th motion

Despins, Ch 11 Trustee/Luc A.

475.00 1.00 475.00 Communicate (in firm) status update call Despins, Ch 11 Trustee/Luc A.

425.00 0.90 382.50 Revise 17th supplemental motion for 2004

Despins, Ch 11 Trustee/Luc A.

425.00 0.20 85.00 confer with R. Flynn regarding Banco Popular and

Despins, Ch 11 Trustee/Luc A.

425.00 0.20 85.00 attention to comments from P. Linsey regarding 17th omnibus 2004 exam, correspond regarding

Despins, Ch 11 Trustee/Luc A.

425.00 0.30 127.50 Ho Wan Kwok, Debtor Review agenda and accompanying information in

Despins, Ch 11 Trustee/Luc A.

495.00 2.30 1,138.50 Confer with K. Mitchell regarding Standard Chartered confidentiality/production issues and Standard Chartered requests (0.5), correspond and confer with D. Barron regarding Standard Chartered information and confidentiality (0.3),

regarding Lexus and confer with PHC1 regarding Lexus (0.2), prepare for conference with S. Jing counsel regarding Lexus (0.3), confer with S. Jing counsel regarding Lexus (0.3), update trustee

review/analyze/revise 17th Rule 2004 motion

Despins, Ch 11 Trustee/Luc A.

495.00 3.20 1,584.00 Correspond with K. Mitchell regarding 17th Rule

Despins, Ch 11 Trustee/Luc A.

425.00 0.50 212.50 Confer with P. Linsey regarding Standard Chartered confidentiality/production issues Despins, Ch 11 Trustee/Luc A.

480.00 0.30 144.00 Multiple correspondence with Attorney Mitchell

Despins, Ch 11 Trustee/Luc A.

550.00 1.00 550.00 Attend zoom conference call with co counsel Linsey, graham, Kinsella, Mitchell and Flynn Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 25 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 97 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 1.00 550.00 Ho Wan Kwok, Debtor

(.3);

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.60 255.00 Attend weekly Kroll/PH meeting Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.30 127.50 Revise 17th supp omnibus 2004 motion

Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.20 40.00 Attention to rule 2004 subpoena service invoices

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.30 127.50 Draft subpoenas for 17th supplemental 2004

Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.10 42.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.40 80.00 Ho Wan Kwok, Debtor Prepare subpoenas and request for production for seventeenth supplemental rule 2004 motion Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor Correspond with Standard Chartered and P.

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.30 127.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.70 297.50 Ho Wan Kwok, Debtor Review analysis and data from Kroll regarding additional targets to add to 17th omnibus motion (.4), correspond with P. Linsey regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.10 42.50 attention to correspondence from L. Song regarding new entity and related individuals Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor Review information from A. Lomas regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with ULX regarding Rockland Trust

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.70 297.50 Ho Wan Kwok, Debtor Revise 17th Supp omnibus motion for 2004 exam to include new entities and banks pursuant Kroll Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 26 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 98 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.10 42.50 attention to information from A. Lomas

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.10 42.50 Reply to SCB regarding foreign injunction call Despins, Ch 11 Trustee/Luc A.

B120 A107 480.00 0.60 288.00 Communicate with Attorney L. Song and Attorney Linsey regarding Lexus status and information for state of last registration and title; review of NY documentation and obtain forms for duplicate title, bill of sale and power of

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Review analysis from Kroll regarding Bofang,

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Review correspondence and information from A. Lomas regarding Vantage West known account Despins, Ch 11 Trustee/Luc A.

B120 A104 495.00 3.00 1,485.00 Ho Wan Kwok, Debtor Attend Kroll investigations update meeting (0.6),

litigation/investigation developments (0.5), correspond with E. Sutton and PHC1 regarding Lexus title issues (0.2), correspond with K.

investigation and review and analyze records and

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor Correspond with P. Linsey regarding the Bofang

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.80 340.00 Revise 17th supplemental omnibus motion for

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.10 42.50 Correspond with P. Linsey regarding revised 17th

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Ho Wan Kwok, Debtor Confer with Standard Chartered and P. Linsey

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Review PNC RFP for specific target pursuant P. Linsey's request, correspond with P. Linsey

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.50 212.50 Review comments from P. Linsey on 17th Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 27 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 99 of

Phase ID B120 Asset Analysis and Recovery

B120 A105 425.00 0.20 85.00 supplemental motion for 2004 exam, revise

Despins, Ch 11 Trustee/Luc A.

Correspond with P. Linsey and Kroll regarding the correct First Bank for the 17th supp 2004

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review yumei hao information and correspondence with her counsel related to

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Correspond with China CITIC regarding meet and

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.60 255.00 Review recent analysis from Kroll related to additional accounts and targets that held Chase

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with E. Cohan regarding service of

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.90 382.50 Research additional PII for new entities

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.40 170.00 Draft correspondence to Chase regarding

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Further correspondence with China CITIC

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.70 385.00 (.4); draft memo to client

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.30 165.00 Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 0.20 40.00 Send bank production to ULX via file transfer;

Despins, Ch 11 Trustee/Luc A.

B120 A107 495.00 2.10 1,039.50 Confer with S. Topping and K. Mitchell regarding Standard Chartered confidentiality issues (0.3), prepare for call and confer with trustee and N. Bassett regarding confidentiality issues and miscellaneous litigation issues/strategy (0.8),

regarding 17th Rule 2004 motion (0.2), attention to PHC1 and D. Barron comments regarding 17th Rule 2004 motion and correspond with K. Mitchell and PH counsel regarding same (0.2), correspond with R. Fingold and assemble/send evidence regarding involvement of Rule 2004

Phase ID B120 Asset Analysis and Recovery

B120 A111 550.00 1.60 880.00 parties at issue in subpoenas (0.4), correspond with E. Sutton and D. Barron regarding Passione

Despins, Ch 11 Trustee/Luc A.

Review and revise draft motion to expedite and draft memo to client with revised motion and motion to sell Greenwich property ( .9); begin revisions to motion to expedite in response to

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond and confer with China CITIC

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Correspond with P. Linsey regarding 17th

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Coordinate with K. Ahumada regarding filing of 17th motion for 2004 exam and service of same Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 0.10 20.00 E-mail with S. Pierce regarding service of 17th

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 1.00 425.00 Research Bofang Investment and Feibo Jiang for

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.40 170.00 Final revisions of 17th omnibus 2004 motion for

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Correspond with K. Ahumada and S. Pierce regarding the filing of the 17th motion for 2004

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.30 127.50 Revise Exhibit B to 17th motion for 2004

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 0.40 80.00 Draft and finalize 17th supplemental motion for filing (.3); send to Attorney Mitchell for review (.1) Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review final version of 17th omnibus 2004 motion, correspond with K. Ahumada to file

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Follow up correspondence with Amex regarding

Despins, Ch 11 Trustee/Luc A.

B120 A101 200.00 1.10 220.00 Serve 17th Rule 2004 motion onto manual

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review prior correspondence with counsel to US Bank/Bento - correspond regarding new requests

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Phase ID B120 Asset Analysis and Recovery

B120 A104 425.00 0.40 170.00 Despins, Ch 11 Trustee/Luc A.

Review analysis by Kroll related to additional records required from First Republic Bank,

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor attention to request from BoA for additional

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.40 170.00 Ho Wan Kwok, Debtor Research relativity for TIN/EIN of New Smoke Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.10 42.50 Ho Wan Kwok, Debtor Correspond with A. Loney of BoA regarding

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.10 42.50 Ho Wan Kwok, Debtor Correspond with S. Smeriglio regarding First

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.10 42.50 Ho Wan Kwok, Debtor Confer with L. Astone regarding First Republic

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor Correspond further with A. Loney from BoA regarding subpoena compliance and additional

Despins, Ch 11 Trustee/Luc A.

B120 A105 495.00 3.40 1,683.00 Ho Wan Kwok, Debtor Correspond with K. Mitchell regarding 17th Rule 2004 motion and service/COS (0.2), prepare for NPM weekly update meeting (0.4), confer with trustee regarding case staffing and strategy (0.3), confer with D. Skalka regarding same (0.2), confer with A. Smith (PAX) regarding Kwok investigation/litigation (0.5), review and analyze District Court decision affirming preliminary injunction regarding harassment by Debtor (1.3),

regarding Stern issues (0.2), attend weekly

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.80 340.00 Review Kroll analysis of new accounts/entities, revise internal tracker for updated subpoenas Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.30 165.00 Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.50 212.50 Ho Wan Kwok, Debtor Meet and confer with China CITIC regarding

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with Amex regarding GFNY

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.10 42.50 Correspond with Kroll regarding update on Amex

Despins, Ch 11 Trustee/Luc A.

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Phase ID B120 Asset Analysis and Recovery

P B120 A108 425.00 0.10 42.50 Ho Wan Kwok, Debtor correspond with E. Cohan regarding service of

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.70 297.50 Ho Wan Kwok, Debtor Review Kroll bank statement analysis related to

correspond with contact regarding updated

P B120 A103 425.00 0.30 127.50 Despins, Ch 11 Trustee/Luc A.

Revise IDB subpoena to include new targets Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.30 60.00 Ho Wan Kwok, Debtor Draft certificate of service for 17th supplemental

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.20 85.00 Ho Wan Kwok, Debtor Review draft certificate for 17th omnibus 2004 motion, correspond with K. Ahumada regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 1.10 467.50 Ho Wan Kwok, Debtor Revise tracking materials related to 2004 motions

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.60 255.00 Ho Wan Kwok, Debtor Review status of CIBC/Canadian Imperial Bank subpoena compliance and status of motion to compel (.4), correspond with R. Flynn and P.

P B120 A103 425.00 1.20 510.00 Despins, Ch 11 Trustee/Luc A.

attention to status of bank production and revise internal materials regarding same (.7), draft outline of next steps/non-compliant institutions

P B120 A105 425.00 0.10 42.50 Despins, Ch 11 Trustee/Luc A.

Correspond with P. Linsey regarding Amex rule

Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor

regarding the cos of 17th rule 2004 motion Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.60 330.00 Ho Wan Kwok, Debtor (.2);

Despins, Ch 11 Trustee/Luc A.

P B120 A105 500.00 0.30 150.00 Ho Wan Kwok, Debtor Communicate (in firm) with Attorney Mitchell regarding status of the CIBC subpoena. Despins, Ch 11 Trustee/Luc A.

P B120 A105 500.00 0.40 200.00 Ho Wan Kwok, Debtor Communicate (in firm) with Attorney K. Mitchell regarding appearances and certificates of service

defendants. Despins, Ch 11 Trustee/Luc A.

P B120 A105 495.00 0.30 148.50 Ho Wan Kwok, Debtor Correspond with K. Mitchell and K. Ahumada Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 31 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 103 of

Phase ID B120 Asset Analysis and Recovery regarding 17th Rule 2004 motion and COS (0.2), correspond with K. Mitchell regarding AMEX Rule

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 1.50 637.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Ho Wan Kwok, Debtor Correspond with P. Linsey and Kroll regarding AmEx production, outline findings of same Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Review analysis of Kroll of recent AmEx production, request additional information regarding missing information for f/u with Amex Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.10 42.50 Correspond with D. Barron regarding Amex

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.30 127.50 Ho Wan Kwok, Debtor Draft and send follow up e-mail detailing missing information and possible account holders to

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with ULX regarding upload of AmEx

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review response from AmEx regarding possible other accounts, follow up with Kroll regarding

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.10 42.50 Correspond with Kroll regarding missing Amex

Despins, Ch 11 Trustee/Luc A.

B120 A107 200.00 0.40 80.00 Draft notice of filing supplemental declaration and revised proposed order for retention of Winne Banta Basralian & Kahn (.3); send to

Despins, Ch 11 Trustee/Luc A.

B120 A104 480.00 0.40 192.00 Review contents of Lexus at Greenwich property for title, search garage for same, locate Monroney sticker for 2020 Land Rover defender and circulate to relevant attorneys, locate wheel

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Correspond with P. Linsey regarding drafting motion to extend removal to district court

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.30 127.50 Review and work with K. Ahumada and S. Pierce regarding certified documents, correspond with

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.30 165.00 Despins, Ch 11 Trustee/Luc A.

Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 32 NEUBERT, PEPE & MONTEITH, P.C. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 104 of 373

Phase ID B120 Asset Analysis and Recovery

B120 A111 550.00 0.70 385.00 Ho Wan Kwok, Debtor Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.20 110.00 Despins, Ch 11 Trustee/Luc A.

P B120 A105 500.00 0.30 150.00 Ho Wan Kwok, Debtor Communicate (in firm) with attorney K. Mitchell regarding filing appearance in avoidance actions against foreign defendants. Despins, Ch 11 Trustee/Luc A.

P B120 A104 500.00 0.90 450.00 Ho Wan Kwok, Debtor Review/analyze certificates of service for avoidance actions against foreign defendants. Despins, Ch 11 Trustee/Luc A.

P B120 A107 495.00 0.90 445.50 Ho Wan Kwok, Debtor Correspond with PHC1 and Kroll team regarding

(0.2), correspond with E.

documents for Lexus (0.2), attend PH litigation team call regarding UAE issues/claims (0.3) Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.30 127.50 Correspond with Bento counsel regarding and

Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.40 80.00 Draft revised notice of filing supplemental declaration for WBBK (.2); send to Attorney Linsey and Attorney Kinsella for review (.2) Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.60 255.00 attention to correspondence from L. Song regarding additional targets for next omnibus 2004 motion (.1), review materials from previous

Commercial Bank (.2), reply to L. Song regarding same (.1), correspond with Kroll requesting additional known entities with bank accounts at Metropolitan Credit Union for updated subpoena

Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.60 255.00 Attention to request from client regarding obtaining certified copies (.1), coordinate,

regarding process (.3), correspond with P. Linsey

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.30 127.50 review materials related to UAE linked parties Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.70 297.50 Analyze government exhibits related to newly identified entities/institutions for 18th Motion for Rule 2004 examination, draft memorandum to

Despins, Ch 11 Trustee/Luc A.

Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 33 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 105 of

Date: 02/24/2025 Doc 4159 Filed 02/24/25 373 NEUBERT, PEPE & MONTEITH, P.C. Entered 02/24/25 23:41:51 Detail Fee Task Code Billing Report Page 105 of

Phase ID B120 Asset Analysis and Recovery

certified copies needed of pleadings for (0.7), prepare and attend Kroll weekly update call regarding investigations (0.7), correspond with K. Mitchell regarding Mauritius litigation (0.2), correspond with R. Fingold regarding Golden Eagle/River Valley motion to quash and proposed resolution (0.2),

Despins, Ch 11 Trustee/Luc A. (0.7), correspond with trustee regarding same (0.1), confer with D. Carnelli

B120 A103 425.00 0.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A. draft 8th motion to extend deadline to remove

B120 A108 425.00 0.30 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A. Call with Citizens regarding updated subpoena

B120 A104 425.00 0.20 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A. Review BoA's R&Os to the updated subpoena

B120 A106 425.00 0.20 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor Correspond with L. Song regarding NAV as

Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor Research contact and related information for

Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor memorandum to P. Linsey regarding status of

Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor Draft and send request for updated documents

Despins, Ch 11 Trustee/Luc A. Review production from First Fidelity Bank for

B120 A104 425.00 0.30 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor Review prior production e-mails from Morgan Stanley, follow up with requests from Kroll

Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor attention to multiple requests for certified copies

5248.001 10/04/2024 19 P B120 A103 480.00 3.80 1,824.00 Begin drafting/revising appellee's brief in

5248.001 10/04/2024 41 P B120 A105 495.00 2.70 1,336.50 Correspond with K. Mitchell regarding motion to

USCA2d No. 24-1271. Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor

Date: 02/24/2025 Doc 4159 Filed 02/24/25 Detail Fee Task Code Billing Report

NEUBERT, PEPE & MONTEITH, P.C. Entered 02/24/25 23:41:51

Phase ID B120 Asset Analysis and Recovery extend deadline to remove civil actions and review motion (0.3), correspond with A. Bongartz and K. Ahumada regarding certified copies of pleadings for Mauritius litigation (0.2),

for remote hearings for matters to be heard on October 8, 2024 (1.3), correspond with trustee

finalize motions and attention to filing of same

A105 425.00 0.20 85.00 Despins, Ch 11 Trustee/Luc A.

Correspond with P. Linsey regarding motion to

Despins, Ch 11 Trustee/Luc A.

A103 495.00 1.30 643.50 Ho Wan Kwok, Debtor

trustee and A. Bongartz questions regarding litigation claims against or related to Qiang Guo Despins, Ch 11 Trustee/Luc A.

A106 495.00 1.00 495.00 Ho Wan Kwok, Debtor Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.40 170.00 Ho Wan Kwok, Debtor Review Kroll analysis related to possible Metropolitan Commercial Bank and multiple

Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor Attention to inquiry from Capital One regarding supplemental request for updated documents,

Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.30 127.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

A104 425.00 1.10 467.50 Ho Wan Kwok, Debtor Review supplemental production of documents

Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

A103 425.00 0.30 127.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

5248.001 10/07/2024 70 P B120 A101 200.00 0.20 40.00

Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor

Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 35 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 107 of

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

B120 A108 425.00 0.20 85.00 Receive and rev correspondence from Capital One regarding supplemental production, reply to

Despins, Ch 11 Trustee/Luc A.

B120 A103 480.00 1.30 624.00 Continue drafting/revising appellee's brief in USCA2d No. 24-1271. Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.60 330.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.70 385.00 (.4);

Despins, Ch 11 Trustee/Luc A.

B120 A104 495.00 3.00 1,485.00 Review and analyze Bofang Investment and Feibo Jiang opposition to 17th Rule 2004 motion (0.2),

Bofang/Jiang financial involvement with debtor

regarding same (0.3), correspond and confer with PHC1 regarding Bofang/Jiang transactions (0.3), prepare for weekly NPM update call with trustee PH team and draft agenda (0.5), attend weekly NPM update call with PH team (1.1), correspond with trustee regarding remote hearing and with

correspond with E. McDaniels regarding transfer of title of Lexus to trustee (0.2), correspond with R. Fingold regarding motion to quash re: Old National Bank and potential resolution (0.2) Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 1.90 807.50 Con't review of Citizens supplemental production, correspond with ULX regarding

Despins, Ch 11 Trustee/Luc A.

B120 A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor Correspond with P. Linsey regarding transfers

Despins, Ch 11 Trustee/Luc A.

B120 A106 425.00 0.30 127.50 Correspond with PH regarding Citizens Bank

Despins, Ch 11 Trustee/Luc A.

B120 A106 425.00 0.30 127.50 Review response and inquiry from N. Bassett regarding previous transactions already included

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Review new request from Kroll regarding additional Chase account located, respond to

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Review correspondence from Chase regarding need for additional information to conduct

Despins, Ch 11 Trustee/Luc A.

Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 36 NEUBERT, PEPE & MONTEITH, P.C. Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 108 of 373

Phase ID B120 Asset Analysis and Recovery

P B120 A104 425.00 0.50 212.50 Review M&T analysis from Kroll, review prior subpoena and revise to include new targets Despins, Ch 11 Trustee/Luc A.

P B120 A102 425.00 0.60 255.00 Research Relativity to PII related to Art Operation

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.20 85.00 Correspond with Contact at M&T regarding service of subpoena and regarding additional

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with Bank of China regarding meet and confer due to lack of subpoena compliance Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.30 127.50 Correspond with P. Linsey regarding response

Despins, Ch 11 Trustee/Luc A.

P B120 A103 480.00 2.20 1,056.00 Continue drafting/revising appellee's brief in USCA2d No. 24-1271. Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.30 165.00 Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.70 385.00 Ho Wan Kwok, Debtor Despins, Ch 11 Trustee/Luc A.

P B120 A106 495.00 5.40 2,673.00 Correspond with trustee regarding hearing (0.1),

various matters (1.2), confer with trustee regarding hearing (0.2), attend hearing on various matters (1.1), correspond with N. Bassett

correspond with K. Mitchell and R. De Palma regarding Bank of China subpoena compliance and motion to compel (0.3), draft 30(b)(6) notice for G Club deposition subpoena and correspond with N. Bassett regarding same (0.8), review and analyze original G Club Rule 2004 subpoena (0.2), revise 30(b)(6) notice for G Club subpoena

correspond with N. Bassett and trustee regarding same (0.4), confer with R. Fingold regarding motion to quash and correspond with K. Mitchell

Despins, Ch 11 Trustee/Luc A.

P B120 A104 425.00 0.50 212.50 Review supplemental Axos production (.4), correspond with ULX regarding upload of same

Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor attention to request from P. Linsey regarding stip with parties that objected to 17th supplemental Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 37 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 109 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

425.00 1.10 467.50 Draft stipulation to resolve objection to 16th rule 2004 motion (.1), correspond with P. Linsey

Despins, Ch 11 Trustee/Luc A.

425.00 0.40 170.00 Ho Wan Kwok, Debtor Confer with contact at Chase regarding updated subpoena and the addition of First Republic Bank Despins, Ch 11 Trustee/Luc A.

Correspond with P. Linsey and Kroll regarding combining First Republic Bank with Chase going

Despins, Ch 11 Trustee/Luc A.

425.00 0.40 170.00 Draft 2004 subpoena for G Club Operations, multiple correspondence with P. Linsey regarding

Despins, Ch 11 Trustee/Luc A.

425.00 0.20 85.00 Review response from Bank of China, review materials from P. Linsey regarding status possible motion to compel and reply to Bank of China Despins, Ch 11 Trustee/Luc A.

200.00 0.20 40.00 Finalize draft of G Club subpoena and send to

Despins, Ch 11 Trustee/Luc A.

425.00 0.60 255.00 Draft materials to supplement Chase in subpoena compliance, including First Republic,

Despins, Ch 11 Trustee/Luc A.

425.00 0.40 170.00 Research additional identifying information pursuant to inquiry from Chase for new entities,

Despins, Ch 11 Trustee/Luc A.

425.00 0.20 85.00 Correspond with K. Ahumada regarding G Club

Despins, Ch 11 Trustee/Luc A.

425.00 0.80 340.00 Confer and correspond with contact at Chase regarding missing target (.3), draft further amended subpoena (.3) and send to Chase (.1), forward to E. Cohan for formal service (.1) Despins, Ch 11 Trustee/Luc A.

425.00 0.30 127.50 Review edited subpoena to G Club and correspondence from P. Linsey (.2), correspond with E. Cohan regarding expedited service of

Despins, Ch 11 Trustee/Luc A.

425.00 0.20 85.00 Review further request from Chase, confer again with contact regarding additional requested

Despins, Ch 11 Trustee/Luc A.

Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 38 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 110 of

Phase ID B120 Asset Analysis and Recovery Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

495.00 1.40 693.00 Correspond and confer with K. Mitchell regarding G Club depo subpoena (0.2), confer with trustee regarding 30(b)(6) notice and revise 30(b)(6) notice and subpoena (0.3), correspond with trustee regarding revised subpoena and draft cover letter (0.2), correspond with J. Sklarz regarding G Club depo subpoena (0.2), attention

5248.001 10/09/2024 68 P B120 A104 425.00 0.20 85.00 Review R&O's from Bank of China, correspond

with P. Linsey about same Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor

memo to attorney Linsey with draft complaint

China R&O's (0.3) Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor

and status report (.2) Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor

responses and objections by Bank of China and correspond with K. Mitchell regarding Bank of

Despins, Ch 11 Trustee/Luc A.

A107 495.00 2.10 1,039.50 Confer with N. Bassett and D. Podhaskie regarding Rule 2004 subpoena (0.3), attend Kroll weekly update call (0.8), correspond with N. Bassett and J. Sklarz regarding G Club subpoena (0.2), correspond with D. Carnelli regarding

revise/work on status report and stipulation to resolve motion to quash filed by River Valley and related parties (0.6), correspond with N. Bassett

Despins, Ch 11 Trustee/Luc A.

A104 425.00 0.60 255.00 Review supplemental production from HSBC,

correspond with ULX regarding upload of same Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 39 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 111 of

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

A103 425.00 0.90 382.50 Despins, Ch 11 Trustee/Luc A.

Yanping Wang and Qiang Guo transfers via HSBC Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor Correspond with China CITIC counsel regarding

Despins, Ch 11 Trustee/Luc A.

A111 550.00 1.10 605.00 (.3); (.3);

Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

A111 550.00 0.60 330.00 (.4);

A111 550.00 0.80 440.00 Despins, Ch 11 Trustee/Luc A.

(.2); (.4);

Despins, Ch 11 Trustee/Luc A.

A111 550.00 0.30 165.00 Draft memorandum to attorney Astone

Despins, Ch 11 Trustee/Luc A.

A105 495.00 2.00 990.00 Ho Wan Kwok, Debtor

investigation findings regarding Yvette Wang and William Je and review and analyze additional records (0.3), prepare for conference with J. Sklarz regarding G Club Rule 2004 deposition and correspond and confer with N. Bassett regarding same (0.5), confer with J. Sklarz and N. Bassett regarding G Club Rule 2004 deposition (0.6), revise draft stipulation to resolve motion to quash and correspond with R. Fingold (Hao/River Valley/Golden Eagle) (0.5), correspond with K.

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.10 42.50 Ho Wan Kwok, Debtor Correspond with P. Linsey regarding stipulation

Despins, Ch 11 Trustee/Luc A.

A103 480.00 2.30 1,104.00 Ho Wan Kwok, Debtor Draft/revise Microsoft subpoena and requests for production (2.1); correspond with Attorney Linsey regarding the same (0.2). Despins, Ch 11 Trustee/Luc A.

Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 40 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 112 of

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Follow up with Capital One regarding updated/supplemental records being sought and

Despins, Ch 11 Trustee/Luc A.

P B120 A101 200.00 0.20 40.00 , fee application edits,

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.70 297.50 Revise updated subpoena for M&T Bank, arrange

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Follow up with counsel to Morgan Stanley

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Follow up with BoA's counsel regarding status of

Despins, Ch 11 Trustee/Luc A.

P B120 A103 425.00 0.50 212.50 Draft revised Barclays Bank subpoena, Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with contact at Barclays Bank regarding new entities/individuals and accounts and whether electronic service of the subpoena

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Follow up with contact at US Bank/Bento regarding status of production of new responsive

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Follow up with Citibank regarding status of

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 F/u with contact at IDB regarding status of

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Follow up with contact at Santander regarding

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.20 85.00 Correspond with counsel to TD Bank regarding

service can be accepted. Despins, Ch 11 Trustee/Luc A.

P B120 A105 425.00 0.20 85.00 Correspond with P. Linsey regarding The Bancorp

Despins, Ch 11 Trustee/Luc A.

P B120 A108 425.00 0.30 127.50 Confer and correspond with counsel to China Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 41 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 113 of

Phase ID B120 Asset Analysis and Recovery CITIC regarding subpoena compliance Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Correspond with contact at First Bank of

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.70 297.50 Ho Wan Kwok, Debtor Research contact for Webster Bank for updated subpoena request (.5), correspond with contact

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.20 85.00 Ho Wan Kwok, Debtor Correspond with contacts from Charles Schwab regarding ability to accept service of an updated

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.20 85.00 Ho Wan Kwok, Debtor

regarding ability to accept service of updated

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.50 212.50 Ho Wan Kwok, Debtor Draft updated subpoena for Kearny Bank to

Despins, Ch 11 Trustee/Luc A.

B120 A103 425.00 0.30 127.50 Ho Wan Kwok, Debtor Draft updated TD Bank subpoena to include new targets, correspond with counsel for TD Bank

Despins, Ch 11 Trustee/Luc A.

B120 A102 425.00 0.70 297.50 Ho Wan Kwok, Debtor Research Relativity for identifying information on

Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.20 85.00 Review analysis and notes from A. Lomas regarding international HSBC accounts and obtaining production of same, respond to same Despins, Ch 11 Trustee/Luc A.

B120 A104 425.00 0.40 170.00 Ho Wan Kwok, Debtor Review internal materials related to Metropolitan

Despins, Ch 11 Trustee/Luc A.

B120 A108 425.00 0.10 42.50 Review response from Schwab regarding service

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.90 495.00 (.7); draft memorandum to attorney Astone

Despins, Ch 11 Trustee/Luc A.

B120 A111 550.00 0.70 385.00 Despins, Ch 11 Trustee/Luc A.

B120 A107 495.00 0.40 198.00 Correspond and confer with N. Bassett regarding G Club deposition (0.2), confer with counsel for Knight Vision regarding limited partnership Date: 02/24/2025 Detail Fee Task Code Billing Report Page: 42 Case 22-50073 Doc 4159 Filed 02/24/25 Entered 02/24/25 23:41:51 Page 114 of

Phase ID B120 Asset Analysis and Recovery

A101 200.00 0.30 60.00 interest (0.2) Despins, Ch 11 Trustee/Luc A.

Phone call with Bankruptcy court clerk regarding certified copies (.1); phone call with Attorney Skalka regarding issues of same (.1); follow up phone call with clerk regarding same (.1)

A103 425.00 0.40 170.00 Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

A103 425.00 0.40 170.00 Ho Wan Kwok, Debtor Review response from Morgan Stanley's counsel, draft response and send specifics of updated

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.10 42.50 Ho Wan Kwok, Debtor Correspond with P. Linsey regarding stipulation

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.20 85.00 Ho Wan Kwok, Debtor Attention to response from Santander regarding status of subpoena compliance, reply to same Despins, Ch 11 Trustee/Luc A.

A108 425.00 0.50 212.50 Ho Wan Kwok, Debtor Confer with counsel to China CITIC regarding

Despins, Ch 11 Trustee/Luc A.

A105 425.00 0.20 85.00 Confer with P. Linsey regarding confidentiality

Despins, Ch 11 Trustee/Luc A.