Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #4224

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re: : :

HO WAN KWOK, et al., :

Debtors.1 : :

-------------------------------------------------------------- x MONTHLY FEE STATEMENT OF KROLL, LLC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM FEBRUARY 1, 2025 THROUGH FEBRUARY 28, 2025

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 Kroll, LLC ("Kroll") hereby submits this monthly

statement (the "Monthly Fee Statement") seeking compensation for services rendered and

reimbursement of expenses incurred as forensic investigators to Luc A. Despins, in his capacity

as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok, for

the period from February 1, 2025 through and including February 28, 2025 (the "Fee Period").

By this Monthly Fee Statement, Kroll respectfully requests payment of 80% of all fees and 100%

of all expenses actually and necessarily incurred for services rendered during the Fee Period, in

the amounts of \$72,129.16 and \$1,537.19, respectively.

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.

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

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

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

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

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

6. Notice of this Monthly Fee Statement will be given by email on the Notice Parties: (i) Luc A. Despins, as chapter 11 trustee for the estate of Ho Wan Kwok (lucdespins@paulhastings.com); (ii) Counsel for the Trustee, (x) Paul Hastings LLP, 200 Park Avenue, New York, New York 10166 (Attn: G. Alexander Bongartz (alexbongartz@paulhastings.com) and Douglass Barron (douglassbarron@paulhastings.com)) and (y) Neubert, Pepe & Monteith, P.C., 195 Church Street, 13th Floor, New Haven, Connecticut 06510 (Attn: Douglas S. Skalka (dskalka@npmlaw.com) and Patrick R. Linsey (plinsey@npmlaw.com)); (iii) the Office of The United States Trustee, Giaimo Federal Building, 150 Court Street, Room 302, New Haven, Connecticut 06510 (Attn: Holley L. Claiborn

(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").

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

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

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

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

In re: :

HO WAN KWOK, et al.,1 : :

Debtors. :

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 17, 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).

Timekeeper Title Service Line Standard Discounted Total Total Fees

Parizek, Pam Managing Director Forensic Investigations \$ 890 \$ 712 4.4 \$ 3,132.80

Barker, James Associate Managing Forensic Investigations \$ 710 \$ 639 6.4 \$ 4,089.60

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

Lazarus, Jordan Senior Manager Forensic Investigations \$ 575 \$ 518 16.1 \$ 8,331.75

Lomas, Adam Senior Manager Forensic Investigations \$ 575 \$ 518 90.7 \$ 46,937.25

Pallas, Xavier Senior Manager Forensic Investigations \$ 575 \$ 518 20.4 \$ 10,557.00

Casemore, James Associate Forensic Investigations \$ 385 \$ 347 3.0 \$ 1,039.50

Spier, Tre Research Analyst Forensic Investigations \$ 245 \$ 221 67.1 \$ 14,795.55

SUMMARY OF COMPENSATION BY PROJECT CATEGORY

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

B110 Case Administration 0.5 \$ 356.00

B120 Asset Analysis and Recovery 204.6 \$ 87,023.45

B160 Fee/Employment Applications 5.0 \$ 2,782.00 B170 Fee/Employment Objections - \$ - B180 Avoidance Action Analysis - \$ - B181 Preference Analysis and Recovery Actions - \$ - B182 Post-Petition Transfers and Recovery Actions - \$ - Other Contested Matters (excl. B190 assumption/rejections motions) - \$ -

00001 General Debtor Representation 5.5 \$

00002 Asset Recovery Investigation and Litigation 163.7 \$

00003 HK USA Adversary Proceeding - \$

00004 Bravo Luck Adversary Proceeding - \$

00006 SN Apartment Adversary Proceeding - \$

00007 Greenwich Land Adversary Proceeding - \$

00009 Mei Guo Adversary Proceeding 40.6 \$

00010 Interpleader Adversary Proceeding - \$

00012 Golden Spring Adversary Proceeding - \$

00013 Mahwah Adversary Proceeding - \$

00015 Lamp Capital Adversary Proceeding - \$

00016 G-Club Adversary Proceeding - \$

00017 Rule of Law Adversary Proceeding - \$

00018 UAE Asset Recovery Actions 0.3 \$

00019 Leading Shine Adversary Proceeding - \$

Expense Category Matter ID Task Code Expense Amount

Database and Research Fees for Asset Recovery Investigation and Litigation Asset Analysis and Recovery 621.59

Valid8 Charges General Debtor Representation Case Administration 915.60

Timekeeper Date Matter Task Narrative Hours Amount

Barker, James 1/23/2025 Asset Recovery Asset Analysis Review documents/case materials - 1.0 \$ 639.00 Investigation and and Recovery transferee list

Barker, James 1/24/2025 Asset Recovery Asset Analysis Correspondence/email - with L.Song 1.3 \$ 830.70 Investigation and and Recovery regarding

Barker, James 1/28/2025 Asset Recovery Asset Analysis Conduct Investigation - reviewed 2.2 \$ 1,405.80 Investigation and and Recovery findings

Casemore, James 1/29/2025 Asset Recovery Asset Analysis Conduct research and analysis on 3.0 \$ 1,039.50 Investigation and and Recovery possible

Barker, James 1/29/2025 Asset Recovery Asset Analysis Correspondence/email - internal tasking 0.8 \$ 511.20 Investigation and and Recovery regarding the

Pallas, Xavier 2/2/2025 Asset Recovery Asset Analysis Conducted Relativity research and 4.3 \$ 2,225.25 Investigation and and Recovery investigative public record research re

Lazarus, Jordan 2/3/2025 General Debtor Fee/Employment Prepare January 2025 monthly fee 0.5 \$ 258.75 Representation Applications statement. Parizek, Pam 2/3/2025 Asset Recovery Asset Analysis Review A. Lomas summary and related 0.2 \$ 142.40 Investigation and and Recovery schedule re: Litigation tranche 1 (.2). Lomas, Adam 2/3/2025 Asset Recovery Asset Analysis Attention to schedules of 2.8 \$ 1,449.00

NPM Law. Lomas, Adam 2/3/2025 Asset Recovery Asset Analysis Telephone call with P. Linsey re: data for 0.4 \$ 207.00

Litigation timing, and other administrative matters.

Lomas, Adam 2/3/2025 Asset Recovery Asset Analysis Data work to capture and quantify 1.6 \$ 828.00

Litigation account.

Spier, Tre 2/3/2025 Asset Recovery Asset Analysis Review and source schedules of 7.2 \$ 1,587.60

Lomas, Adam 2/4/2025 Asset Recovery Asset Analysis Analysis of the nature and mechanics of 1.3 \$ 672.75 Investigation and and Recovery transfers to certain potential

etc.); compose related email to NPM Law [P. Linsey].

Pallas, Xavier 2/4/2025 Asset Recovery Asset Analysis Conducted Relativity research and 1.6 \$ 828.00 Investigation and and Recovery investigative public record research re

Timekeeper Date Matter Task Narrative Hours Amount

Lazarus, Jordan 2/4/2025 Asset Recovery

and Recovery Review and respond to correspondence

and Recovery Review and source schedules of

and Recovery Review of research findings with respect

and Recovery Review A. Lomas summary and related schedule re:

entities for further inquiry (.1) 0.3 \$

and Recovery Data work to capture and quantify

Lazarus, Jordan 2/5/2025 General Debtor

Applications Prepare January 2025 monthly fee

and Recovery Review and source schedules of

Administration Review staff communications re:

and Recovery Review schedules to complaint in

and Recovery Compose email to Paul Hastings [L. Song and D. Barron] with questions re:

and Recovery Respond to inquiry from NPM Law [D.

related review of transaction data. 0.3 \$

Lazarus, Jordan 2/6/2025 Asset Recovery

and Recovery Review and respond to correspondence

Timekeeper Date Matter Task Narrative Hours Amount

and Recovery Respond to inquiry from NPM Law [P.

transaction and document review. 0.7 \$

and Recovery Review Amended Complaints for

and Recovery Respond to inquiry from Paul Hastings

and Recovery Review and source schedules of

and Recovery Continued attention to schedules of

and Recovery Analysis to determine which

documents supporting transfers). 1.4 \$

per request of NPM Law [D. Skalka]; related email to NPM Law. 0.3 \$

and Recovery Prepare schedule of transfers to the

related email to NPM Law [K. Mitchell]. 0.7 \$

Lazarus, Jordan 2/7/2025 Asset Recovery

and Recovery Review and respond to correspondence

and Recovery Prepare schedules of transfers to

and Recovery Respond to inquiry from NPM Law [D. Skalka] re: addresses for transferees for 0.3 \$

and Recovery Prepare schedules of transfers to

and Recovery Conducted Relativity research and

Timekeeper Date Matter Task Narrative Hours Amount

Lomas, Adam 2/7/2025 Asset Recovery Asset Analysis Instructions to T. Spier re: review of 0.2 \$

Investigation and and Recovery documents with respect to identifying

Spier, Tre 2/7/2025 Asset Recovery Asset Analysis Review and analysis of 1.4 \$

Investigation and and Recovery account checks; related updates to master Litigation transaction file. Lomas, Adam 2/8/2025 Asset Recovery Asset Analysis Prepare additional schedules of 1.7 \$

Investigation and and Recovery for new and

request from NPM Law. Pallas, Xavier 2/8/2025 Asset Recovery Asset Analysis Conducted Relativity research and 5.4 \$

Investigation and and Recovery investigative public record research re

Pallas, Xavier 2/9/2025 Asset Recovery Asset Analysis Conducted Relativity research and 0.9 \$

Investigation and and Recovery investigative public record research re

Lomas, Adam 2/9/2025 Asset Recovery Asset Analysis Prepare additional schedules of 1.4 \$

email to NPM Lay [D. Skalka].

Lomas, Adam 2/10/2025 Asset Recovery Asset Analysis Respond to inquiry from Paul Hastings 0.5 \$

Investigation and and Recovery [L. Song] re: transaction counts; related Litigation calculations and analyses.

and Recovery Review updated schedules re new and reveised avoidance complaints (.2). 0.2 \$

Lomas, Adam 2/10/2025 Asset Recovery Asset Analysis Reconciliation of identified transfers with 2.9 \$

Investigation and and Recovery respect to certain

Lomas, Adam 2/10/2025 Asset Recovery Asset Analysis Revisions and continued attention to 3.0 \$

Investigation and and Recovery schedules of

NPM Law [D. Skalka and P. Linsey]. Lazarus, Jordan 2/10/2025 General Debtor Fee/Employment Prepare January 2025 monthly fee 1.0 \$

Representation Applications statement. Pallas, Xavier 2/10/2025 Asset Recovery Asset Analysis Conducted Relativity research and 1.3 \$

Investigation and and Recovery investigative public record research for

Lazarus, Jordan 2/10/2025 Asset Recovery Asset Analysis Review and respond to correspondence 0.4 \$

Investigation and and Recovery with NPM Law re: numerous

and related matters. Lomas, Adam 2/10/2025 Asset Recovery Asset Analysis Respond to inquiry from NPM Law [P. 0.6 \$

Investigation and and Recovery Linsey] re: transfers to

Asset Recovery Asset Analysis Inc. Analysis of certain transfers to 0.7 \$

Timekeeper Date Matter Task Narrative Hours Amount

Lazarus, Jordan 2/11/2025 Asset Recovery

and Recovery Review and respond to correspondence

and Recovery Analysis of certain transfers to 2.6 \$ 1,345.50 Lazarus, Jordan 2/11/2025 General Debtor

Applications Prepare January 2025 monthly fee

account checks; related updates to master

and Recovery Revisions and continued attention to

NPM Law [D. Skalka and P. Linsey]. 0.6 \$ 310.50

and Recovery Respond to inquiry from NPM Law [P.

certain avoidance defendants. 0.8 \$ 414.00

and Recovery Analysis of certain transfers to 1.0 \$ 517.50 Pallas, Xavier 2/11/2025 Asset Recovery

and Recovery Conducted Relativity research and

and Recovery Respond to inquiry from NPM Law [D. Skalka] re: clarification of transferor of

and Recovery Analysis of transfers with respect to

compose related email to NPM Law [P.

and Recovery Respond to inquiry from NPM Law [P.

account checks; related updates to master

and Recovery Review comments re:

and Recovery Compose email to NPM Law [D. Skalka] re:

Timekeeper Date Matter Task Narrative Hours Amount

Lomas, Adam 2/12/2025 Asset Recovery Asset Analysis Prepare additional schedules of transfers 1.9 \$

Investigation and and Recovery for additional

email to NPM Law [D. Skalka and P. Linsey].

Lomas, Adam 2/12/2025 Asset Recovery Asset Analysis Prepare revised schedules of 0.4 \$

Investigation and and Recovery compose related email to NPM Litigation Law [P. Linsey].

Parizek, Pam Representation Fee/Employment Applications Review draft Fee Statement for January

Lazarus, Jordan 2/12/2025 General Debtor Fee/Employment Prepare January 2025 monthly fee 1.5 \$

Representation Applications statement. Lomas, Adam 2/12/2025 Asset Recovery Asset Analysis Review documents produced by The 1.4 \$

Investigation and and Recovery related update of Litigation inventory of Debtor-related bank accounts. Lomas, Adam 2/12/2025 Asset Recovery Asset Analysis Review research results for 0.6 \$

Investigation and and Recovery with respect to certain

email to Paul Hastings [E. Sutton].

and Recovery Various email correspondence with Paul Hastings [L. Song] re: documents 0.9 \$

statements and documents.

Lomas, Adam 2/13/2025 Asset Recovery Asset Analysis Additional attention/revisions to 0.4 \$

Investigation and and Recovery schedules of transfers to

Law [P. Linsey].

Lomas, Adam Investigation and Asset Analysis

Litigation inquiry/request from NPM Law [N. Kinella]. Lomas, Adam 2/13/2025 Asset Recovery Asset Analysis Data work with respect to the creation of 5.2 \$

Investigation and and Recovery a new schedule/table of itemized

transfers). Lazarus, Jordan 2/13/2025 Asset Recovery Asset Analysis Review and respond to correspondence 0.2 \$

Investigation and and Recovery with NPM Law re: numerous

and related matters. Lomas, Adam 2/13/2025 Asset Recovery Asset Analysis Prepare additional schedules of transfers 1.8 \$

Investigation and and Recovery for additional

email to NPM Law [P. Linsey].

Spier, Tre 2/13/2025 Asset Recovery Asset Analysis Review of document productions from 1.3 \$

Investigation and and Recovery related updates to Litigation inventory of Debtor-related bank accounts.

Timekeeper Date Matter Task Narrative Hours Amount

and Recovery Respond to inquiry from Paul Hastings [L. Song] re: LLC payroll records; related review of 2.8 \$

and Recovery Telephone conversation with P. Linsey

and Recovery Respond to inquiry from NPM Law [D.

Lazarus, Jordan 2/18/2025 Asset Recovery

productions for seal markings;

updates to master transaction file. 3.8 \$

and Recovery Coordinate response to inquiry from

and Recovery Review communications re:

and Recovery Respond to inquiry from NPM Law [P. Linsey] re: additional identified transfers

LLP; prepare related schedule and analysis. 1.8 \$

and Recovery Instructions to T. Spier for capture of

Lazarus, Jordan 2/19/2025 Asset Recovery

and Recovery Review and respond to correspondence

Applications Review/approve final exhibits and

Timekeeper Date Matter Task Narrative Hours Amount

Lomas, Adam 2/21/2025 Mei Guo Asset Analysis Meeting with Paul Hastings [L. Song 0.4 \$

Adversary and Recovery and D. Barron] re: documents in recent

date. Lazarus, Jordan 2/21/2025 Mei Guo Asset Analysis Phone call with L. Song and A. Lomas 0.4 \$

Adversary and Recovery re:

Proceeding matters. Spier, Tre 2/21/2025 Mei Guo Asset Analysis Review and analysis of

Adversary and Recovery account transactions.

Asset Recovery Asset Analysis Upload of bank statements into bank 0.3 \$

Investigation and and Recovery statement analysis tool.

Lomas, Adam 2/21/2025 Mei Guo Asset Analysis Review and analysis of 4.6 \$

Adversary and Recovery transactions; related updates to Proceeding master transaction file. Lomas, Adam 2/24/2025 Mei Guo Asset Analysis Review and analysis of 3.7 \$

Adversary and Recovery transactions; related updates to Proceeding master transaction file. Lomas, Adam 2/24/2025 Asset Recovery Asset Analysis Respond to inquiry from Paul Hastings 1.1 \$

Investigation and and Recovery [S. Maza] re: funds Litigation bank accounts.

Lazarus, Jordan 2/24/2025 Asset Recovery Asset Analysis Review of correspondence from A. 0.2 \$

Investigation and and Recovery Lomas re: closure of

Lomas, Adam 2/24/2025 Mei Guo Asset Analysis Prepare schedules summarizing active 4.1 \$

Proceeding and Recovery and transaction

email to Paul Hastings [L. Song].

Lazarus, Jordan 2/24/2025 Asset Recovery Asset Analysis Preparation of updated 2.9 \$

Investigation and and Recovery transactional analysis; correspondence Litigation with P. Linsey and A. Lomas re: related matters. Lazarus, Jordan 2/24/2025 Asset Recovery Asset Analysis Analysis of

Investigation and and Recovery preparation of Litigation correspondence with A. Lomas and L. Song re: related matters. Lazarus, Jordan 2/25/2025 Asset Recovery Asset Analysis Review of 0.3 \$

Investigation and and Recovery filed.

Spier, Tre 2/26/2025 Asset Recovery Asset Analysis Review and analysis of 2.0 \$

Investigation and and Recovery bank account transactions; related

Asset Recovery Asset Analysis updates to master transaction file.

Investigation and and Recovery transactions into master transaction file Litigation for review/analysis. Lomas, Adam 2/26/2025 Mei Guo Asset Analysis Respond to inquiry from Paul Hastings 2.4 \$

Adversary and Recovery [L. Song] re: certain

document and transaction review. Lazarus, Jordan 2/26/2025 Asset Recovery Asset Analysis Analysis of

Investigation and and Recovery preparation of Litigation correspondence with A. Lomas and L. Song re: related matters.

Timekeeper Date Matter Task Narrative Hours Amount

Pallas, Xavier 2/27/2025 Asset Recovery

and Recovery Conducted Relativity research to identify

Lazarus, Jordan 2/27/2025 Asset Recovery

and Recovery Review correspondence with K. Mitchell

transactional data and related matters. 0.2 \$ 103.50 Lazarus, Jordan 2/27/2025 Asset Recovery

master transaction file. 3.9 \$ 859.95

and Recovery Correspondence/email with Kroll team re:

and Recovery Respond to inquiry from NPM Law [K.

updates to master transaction file. 1.3 \$ 672.75

transaction file for review/analysis. 0.6 \$ 310.50

and Recovery Review commuinications re:

additional information (.3). 0.3 \$ 213.60

and Recovery Review status updates re:

and Recovery Correspondence/email with I.Jones

Pallas, Xavier 2/28/2025 Asset Recovery

and Recovery Conducted Relativity research to identify

Total Hours and Amount: 210.1 \$ 90,161.45