Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #4203

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

MONTHLY FEE STATEMENT OF KOBRE & KIM (GCC) LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM DECEMBER 1, 2024 THROUGH DECEMBER 31, 2024

In accordance with the Order Establishing Procedures for Interim Compensation and

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

2094] (the "Interim Compensation Order"),2 Kobre & Kim (GCC) LLP ("Kobre & Kim") hereby

submits this monthly statement (the "Monthly Fee Statement") seeking compensation for

services rendered and reimbursement of expenses incurred as special counsel in the United Arab

Emirates to Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in

the chapter 11 case of Ho Wan Kwok, for the period from December 1, 2024 through and

including December 31, 2024 (the "Fee Period"). By this Monthly Fee Statement, Kobre & Kim

respectfully requests payment of 80% of all fees and 100% of all expenses actually 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 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 shall have the meanings ascribed to such terms in the Interim Compensation Order.

necessarily incurred for services rendered during the Fee Period, in the amounts of \$33,096.40 and \$3,672.49, respectively.

1. Attached hereto as Exhibit A is a timekeeper summary that includes the position, hours, rate, and total fees earned for each Kobre & Kim individual who provided services during the Fee Period.

2. Attached hereto as Exhibit B is Kobre & Kim's fee statement for services provided during the Fee Period.

3. Notice of this Monthly Fee Statement will be given by email on the Notice Parties: (i) Luc A. Despins, as chapter 11 trustee for the estate of Ho Wan Kwok (lucdespins@paulhastings.com); (ii) Counsel for the Trustee, (x) Paul Hastings LLP, 200 Park Avenue, New York, New York 10166 (Attn: G. Alexander Bongartz (alexbongartz@paulhastings.com) and Douglass Barron (douglassbarron@paulhastings.com)) and (y) Neubert, Pepe & Monteith, P.C., 195 Church Street, 13th Floor, New Haven, Connecticut 06510 (Attn: Douglas S. Skalka (dskalka@npmlaw.com) and Patrick R. Linsey (plinsey@npmlaw.com)); (iii) the Office of The United States Trustee, Giaimo Federal Building, 150 Court Street, Room 302, New Haven, Connecticut 06510 (Attn: Holley L. Claiborn (holley.l.claiborn@usdoj.gov)); (iv) counsel for the Official Committee of Unsecured Creditors, Pullman & Comley, LLC, 850 Main Street, 8th Floor, PO Box 7006, Bridgeport, Connecticut 06601-7006 (Attn: Irve J. Goldman (igoldman@pullcom.com); and (v) counsel for Pacific Alliance Asia Opportunity Fund L.P., O'Melveny & Myers LLP, 7 Times Square, New York, New York 10036 (Attn: Peter Friedman (pfriedman@omm.com) and Stuart M. Sarnoff (ssarnoff@omm.com) (collectively, the "Notice Parties").

4. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Kobre & Kim (Attn: Paul Hughes (Paul.Hughes@kobrekim.com) and (ii) the Notice Parties by email no later than April 1, 2025 at 4:00 p.m. (prevailing Eastern Time) (the "Objection Deadline"), setting forth the nature of the objection and the specific amount of fees or expenses at issue.

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

6. To the extent that an objection to this Monthly Fee Statement is filed and received on or before the Objection Deadline, the estate shall withhold payment of that portion of this Monthly Fee Statement to which the objection is directed and promptly pay the remainder of the fees and expenses in the percentages set forth above. To the extent such an objection is not resolved, it shall be preserved and scheduled for consideration at the next interim fee application hearing.

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re: : :

HO WAN KWOK, et al.,1 : :

Debtors. : :

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The undersigned hereby certifies that on the date hereof, the foregoing Monthly Fee Statement was electronically filed. In addition, a copy of the Monthly Fee Statement was served by email on the Notice Parties. Parties may access this filing through the Court's CM/ECF system.

Dated: March 11, 2025 By: /s/ G. Alexander Bongartz

New York, New York G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6000 alexbongartz@paulhastings.com

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

Litigation Assistant 0.8 450.00 360.00

PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Rate Hours Amount

PRH Confer Nada Oteifi and review communications Paul Hastings team. \$1,875.00 0.3 \$562.50 NAE Attention to correspondence from client and Kroll. 1,050.00 0.2 210.00

PRH Review further communications Kroll. 1,875.00 0.2 375.00 NAE Respond to Kroll email and liaise with team on timing for client/Kroll call. 1,050.00 0.2 210.00

PRH Prepare for Kroll call and confer Nada Oteifi. 1,875.00 0.5 937.50 PRH Attend Kroll call. 1,875.00 0.5 937.50 PRH Attend internal strategy call regarding immediate next

ERB Prepare for and attend call with Kroll and Paul Hastings; follow up correspondence. 1,300.00 0.8 1,040.00 ERB Consider priority action items and next steps following

NAE Call with Kroll and client. 1,050.00 0.5 525.00 NAE Team debrief and consider list of deliverables before

NAE Confer with team to obtain 1,050.00 0.2 210.00

SLB Confer with Nadia Simpson and Michael Brasky

(0.5). Under attorney supervision, analyse any and all case

SB Identify and monitor ongoing proceedings for case

PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Rate Hours Amount

PRH Review and approve email Kroll and review response. 1,875.00 0.3 562.50 PRH Review communications regarding next steps and confer Emily Beirne. 1,875.00 0.3 562.50 PRH Review and approve updates to Paul Hastings team and

ERB Attention to additional documents and information provided by Kroll. 1,300.00 0.6 780.00 ERB Consider issues of 1,300.00 0.8 1,040.00 NAE Correspond with client regarding 1,050.00 0.3 315.00 NAE Correspond with Kroll on requested documents. 1,050.00 0.3 315.00 NAE Review information and documents received from

NRS Attention to client documents in relation to 585.00 0.3 175.50 SB Attention to key correspondence and documents to expedite work by legal team. 450.00 0.2 90.00

JDC Confer internally regarding status and next steps. 1,875.00 0.5 937.50 NAE Further review of documents received from Kroll. 1,050.00 0.4 420.00 NRS Attention to client documents in relation to 585.00 0.5 292.50

PRH Review internal communications regarding updated

PRH Update from Kroll and confer team regarding next

NAE Review further information and documents received from Kroll and confer with Emily Beirne and Nadia

NRS Attention to client documents in relation to 585.00 0.5 292.50 PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Rate Hours Amount

PRH Liaise with Emily Beirne and Nada Oteifi regarding next steps, review and approve email out to client. 1,875.00 0.5 937.50 NAE Liaise with team on next steps and client update. 1,050.00 0.3 315.00 NAE Explore further investigation areas based on Kroll's

and prepare table of the same for attorney review. 585.00 0.7 409.50

and prepare table of the same for attorney review. 585.00 0.9 526.50

PRH Finalising and approving detailed client update. 1,875.00 0.3 562.50 ERB Internal discussion regarding next steps; prepare brief update email to client. 1,300.00 0.7 910.00 NAE Review Kroll's findings and draft follow up queries. 1,050.00 0.7 735.00

PRH Review and approve external communications with Paul Hastings and confer internally. 1,875.00 0.5 937.50

NAE Attention to update from client as to US actions and confer with Emily Beirne. 1,050.00 0.4 420.00

PRH Prepare for and attend strategy call ahead of call with

PRH Review and approve agenda and client update. 1,875.00 0.2 375.00 PRH Strategy call with Luc and team and attend to follow

PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Rate Hours Amount

ERB Prepare for an attend internal discussion regarding next steps and priority items in 1,300.00 0.6 780.00 ERB Prepare for an attend update call to discuss next steps

NAE Attend strategy client call and follow up with team on

NAE Consider strategy and prep for client call. 1,050.00 0.5 525.00 NRS Prepare for upcoming client call and prepare agenda on the same for case team review. 585.00 0.5 292.50

NRS Attend client call and prepare key points for case teams

ERB Prepare draft update to client including 1,300.00 0.7 910.00

with Nadia Simpson. NRS Prepare client email regarding UAE strategy for

SB Identify key legal materials to expedite work by legal

NAE Review draft client email and liaise with team on potential UAE counsel. 1,050.00 0.3 315.00

NRS Finalise key notes and action items from client call for attorney team review. 585.00 0.6 351.00

PRH Review email from Paul Hastings and confer team. 1,875.00 0.3 562.50 PRH Review, amend and approve client update. 1,875.00 0.3 562.50

PRH Review, amend and approve email Kroll. 1,875.00 0.2 375.00 PRH Review update from Kroll. 1,875.00 0.2 375.00 PRH Review updated communications regarding next steps. 1,875.00 0.3 562.50 PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

Date/Tkpr Description of Work Rate Hours Amount

NAE Revise draft email requesting Kroll to conduct targeted

NRS Prepare email to Kroll regarding new and outstanding investigations for attorney review. 585.00 0.5 292.50

PRH Review update Paul Hastings team. 1,875.00 0.2 375.00

ERB Attention to correspondence received. 1,300.00 0.2 260.00

Total Current Fees & Disbursements \$45,042.99