Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #4252

METADATA

Defendant: Guo Wengui / Miles Guo / Ho Wan Kwok
Court: CTB
Case No.: 22-50073
ECF #: 4252
Type: ORDER
Filed: 2022-07-06

FULL TEXT

## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|--------|-------------------------| | In re: | : : | Chapter 11 | | | : | | | 1 HO WAN KWOK, et al., | : : | Case No. 22-50073 (JAM) | | Debtors. | : | (Jointly Administered) | | ----------------------------------------------------------- | : x | |

# **NINETEENTH SUPPLEMENTAL OMNIBUS MOTION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER UNDER BANKRUPTCY RULE 2004 AND LOCAL RULE 2004-1 AUTHORIZING DISCOVERY WITH RESPECT TO ADDITIONAL BANKS, HOSPITALITY COMPANIES, AND ADDITIONAL ENTITIES ASSOCIATED WITH AND/OR DOING BUSINESS WITH DEBTOR AND DEBTOR-RELATED PERSONS**

Luc A. Despins, in his capacity as the Chapter 11 Trustee (the "Trustee") appointed in the above-captioned chapter 11 case (the "Case") of Ho Wan Kwok (the "Debtor"), by and through his undersigned counsel, pursuant to Federal Rule of Bankruptcy Procedure 2004(a) (the "Bankruptcy Rules") and Local Bankruptcy Rule 2004-1 (the "Local Rules"), hereby applies (the "Application" or "Motion") to conduct the examination of certain banks and certain entities associated with the Debtor at or with which the Trustee believes the Debtor, Debtor-associated shell companies, and/or Related Persons conducted business relevant to the estate of the Debtor (collectively, the "Examinees"), as such Examinees are identified in **Exhibit B**, attached hereto. **Please take notice that the deadline to object to this Application is April 1, 2025, and in the**

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).

**absence of a timely filed objection, the proposed order filed herewith as Exhibit A (the "Proposed Order") may enter without further notice and hearing**. In support of his Application, the Trustee respectfully states as follows:

#### **PRELIMINARY STATEMENT**

1. The Trustee, in furtherance of his duties and responsibilities under the order authorizing the appointment of a chapter 11 trustee dated July 6, 2022, (*see* ECF. No. 465, at 14, hereinafter referred to as the "Trustee Order"), continues his investigation into the Debtor's financial and business affairs to determine whether additional estate assets exist and to recover upon those assets for the benefit of the Debtor's estate.

2. The Trustee's investigation has identified more entities with possible knowledge of the Debtor's assets and financial activities, and the Trustee seeks to further his investigation through additional Bankruptcy Rule 2004 discovery of these Examinees.

3. The Trustee believes that the Examinees have access to and knowledge of information relating to the Debtor's assets, financial affairs, and potential financial interests in various corporate entities related to the Debtor, his family, or his associates, including, without limitation, entities that are the Debtor's alter egos.

4. The Trustee has submitted multiple Bankruptcy Rule 2004 motions granted by the Court, including one directed at legal and financial firms believed to have advised the Debtor and related entities and individuals (ECF No. 637, the "Advisors 2004 Motion"), one directed at entities and individuals believed to be affiliated with, controlled by, or otherwise connected to the Debtor (the "Affiliates 2004 Motion"), the Trustee's First Supplemental Omnibus Motion dated September 7, 2022 (the "First Omnibus Motion"), the Trustee's Second Supplemental Omnibus Motion dated November 18, 2022 (the "Second Omnibus Motion"), the Trustee's Third

Supplemental Omnibus Motion dated December 21, 2022 (the "Third Omnibus Motion,"), the Trustee's Fourth Supplemental Omnibus Motion dated March 24, 2023 (the "Fourth Omnibus Motion"), the Trustee's Fifth Supplemental Omnibus Motion dated May 15, 2023 (the "Fifth Omnibus Motion"), the Trustee's Sixth Supplemental Omnibus Motion dated August 11, 2023 (the "Sixth Omnibus Motion,"), the Trustee's Seventh Supplemental Omnibus Motion dated October 10, 2023 (the "Seventh Omnibus Motion"), the Trustee's Eighth Supplemental Omnibus Motion dated November 2, 2023 (the "Eighth Omnibus Motion"), the Trustee's Ninth Supplemental Omnibus Motion dated November 6, 2023 (the "Ninth Omnibus Motion"), the Trustee's Tenth Supplemental Omnibus Motion dated December 14, 2023 (the "Tenth Omnibus Motion"), the Trustee's Eleventh Supplemental Omnibus Motion dated January 16, 2024 (the "Eleventh Omnibus Motion"), the Trustee's Twelfth Supplemental Omnibus Motion dated January 30, 2024 (the "Twelfth Omnibus Motion"), the Trustee's Thirteenth Supplemental Omnibus Motion dated March 21, 2024 (the "Thirteenth Omnibus Motion"), the Trustee's Fourteenth Supplemental Omnibus Motion dated March 25, 2024 (the "Fourteenth Omnibus Motion"), the Trustee's Fifteenth Supplemental Omnibus Motion dated May 16, 2024 (the "Fifteenth Omnibus Motion"), the Trustee's Sixteenth Supplemental Omnibus Motion dated August 13, 2024 (the "Sixteenth Omnibus Motion"), the Trustee's Seventeenth Omnibus Motion dated September 30, 2024 (the "Seventeenth Omnibus Motion") and the Trustee's Eighteenth Omnibus Motion dated February 12, 2025 (the "Eighteenth Omnibus Motion", and together with the Advisors 2004 Motion, the Affiliates 2004 Motion, the First Omnibus Motion, the Second Omnibus Motion, the Third Omnibus Motion, the Fourth Omnibus Motion, the Fifth Omnibus Motion, the Sixth Omnibus Motion, the Seventh Omnibus Motion, the Eighth Omnibus Motion, the Ninth Omnibus Motion, the Tenth Omnibus Motion, the Eleventh Omnibus Motion, the Twelfth Omnibus Motion, the Thirteenth Omnibus Motion, the Fourteenth Omnibus Motion, the Fifteenth Omnibus Motion, the Sixteenth Omnibus Motion, and the Seventeenth Omnibus Motion, collectively, the "2004 Motions"). The discovery requested herein will supplement and augment inquiries the Trustee has already begun, as well as open additional avenues of investigation and potential discovery of assets.

5. In the interest of brevity, the Trustee incorporates the 2004 Motions herein by reference and makes them a part hereof. All capitalized terms not defined herein shall have the meanings ascribed to them in the 2004 Motions.

#### **JURISDICTION AND VENUE**

6. The Court has jurisdiction to entertain this application under 28 U.S.C. §§ 157 and 1334. Venue to hear this Application is proper in accordance with 28 U.S.C. §§ 1408 and 1409.

7. This Application is a core proceeding pursuant to, *inter alia*, 28 U.S.C. § 157(b)(2) (A), (E), and (F).

#### **THE EXAMINEES**

8. The Examinees include banks and financial institutions where the Trustee understands that businesses and individuals associated with the Debtor engaged in transactions related to the Debtor's financial affairs; hospitality companies which have received transfers and provided services to Debtor-Related Persons, and businesses and entities associated with the Debtor and Debtor-Related Persons. The Examinees were not included in the prior 2004 Motions and may have material information concerning the Debtor's assets and financial condition.

9. More specifically, the Examinees are as follows:

(a) The banks and/or financial institutions are **Bankwell Bank, Avidia Bank, and Barclays PLC2** . The Trustee understands that at least one Debtor-associated individual or entity has maintained one or more account(s) at each of these Examinees and/or that such Examinees have assisted with or facilitated transfers between other Debtor-related accounts held at previously identified financial institutions.

(b) **Uber Technologies Inc.** is an entity which has received payments from various Related Persons, including but not limited to the Debtor's son, Qiang Guo (a/k/a Mileson Guo), and which may have information regarding the location of Related Persons and assets that may be property of the estate;

(c) The hospitality companies that may have done business with the Debtor and Related Persons are: **Marriot International, Inc.**, **Wyndham Hotels & Resorts, Inc.**, and **Choice Hotels International, Inc.** The Trustee understands that these Examinees received significant transfers from the Debtor and Related Persons. The Trustee intends to investigate, among other things, the disposition of these funds and the time-frames and locations at which the funds were used. Information regarding these transactions may also shed light on the location of Related Persons and assets that may be property of the estate;

(d) The businesses, entities, and individuals that may have done business with the Debtor, Debtor's family members, associates and other Related Persons are:

> i. **Joseph Rocco, Michael Rocco, Jr., and Frank Rocco**, **in their respective capacities as executors of the Estate of Anna Sofia Rocco (the "Estate"),**

2 The Court previously authorized the Trustee to undertake the Rule 2004 examination of an affiliate financial institution of Barclays PLC, *i.e.*, Barclays Bank PLC. [ECF Nos. 839 and 866] Because the Trustee's motion with respect to that examination did not expressly request authority to serve Rule 2004 subpoenas on the affiliates of examinees (as the Trustee customarily requests in his more recently filed motions to pursue Rule 2004 examinations), out of an abundance of caution, the Trustee further requests authority to examine Barclays PLC. The Trustee understands that Related Persons engaged in financial transactions related to the Debtor's financial affairs at Barclays PLC or its affiliates.

which Estate, upon information and belief, owns 1 Loch Lane, Greenwich, Connecticut (the "1 Loch Lane Property"). The Trustee understands that Related Persons, including the Debtor's alleged wife, reside at or utilize the 1 Loch Lane Property, and that the (considerable) rent for such property is purportedly paid by third parties. The Trustee intends to investigate, among other things, who utilizes this property, for what purpose, how any rent payments are funded, and whether the source of such funding is property of the estate; and

ii. **The Royale Condominium, By its Board of Managers**, which is the condominium association for a residential building located at 188 East 64th Street, New York, NY 10065, in which building Yanping "Yvette" Wang owns a condominium apartment (the "Wang Apartment") through a shell company. The Trustee intends to investigate, among other things, the current use of the Wang Apartment and sources of funding for the Wang Apartment.

#### **RELIEF REQUESTED**

10. The Trustee seeks entry of an order, in substantially the form of the Proposed Order, pursuant to Bankruptcy Rule 2004(a) and Local Rule 2004-1, authorizing the Trustee to conduct the examination of the Examinees included on **Exhibit B**.

#### **BASIS FOR RELIEF REQUESTED**

11. Pursuant to Rule 2004(a), on application of a party in interest, the Court may order the examination of any person or entity. The scope of an examination authorized under Rule 2004 is exceedingly broad and may relate to the "acts, conduct, or property or to the liabilities and financial condition of the debtor, or to any matter which may affect the administration of the debtor's estate." Fed. R. Bankr. P. 2004(b).

12. "The purpose of a Rule 2004 examination is to assist a party in interest in determining the nature and extent of the bankruptcy estate, revealing assets, examining transactions and assessing whether wrongdoing has occurred." *In re Transmar Commodity Group Ltd.*, 2018 WL 4006324, at \*4 (Bankr. S.D.N.Y. Aug. 17, 2018) (internal quotation and citation omitted). This includes revealing the nature and extent of the estate and in discovering assets of the debtor that may have been intentionally or unintentionally concealed. *See In re Bennett Funding Group, Inc.*, 203 B.R. 24, 27-28 (Bankr. N.D.N.Y. 1996). *See also In re Millennium Lab Holdings II, LLC*, 562 B.R. 614, 626 (Bankr. D. Del. 2016) ("Legitimate goals of Rule 2004 examinations include discovering assets, examining transactions, and determining whether wrongdoing has occurred." (internal quotation and citation omitted)).

13. In the declaration he submitted on March 20, 2022 in support of the filing of this case, the Debtor represented that among the purposes for filing his chapter 11 case were "to … (b) afford stakeholders an efficient opportunity to investigate [his] assets, liabilities, and financial affairs, given what [he] perceive[d] to be misunderstandings in that regard; [and] (c) establish what assets are estate property and, in turn, available for distribution to holders of allowed claims . . . ." (Debtor's Declaration, ¶3). The investigation the Trustee seeks to perform is directly relevant to these stated purposes in that it will help the Trustee identify the Debtor's assets and liabilities in order to make distributions to creditors.

14. The areas for inquiry herein are part of the Trustee's ongoing investigative efforts. As the investigation evolves, new avenues of inquiry become apparent and the need for additional discovery of persons, entities and areas of examination arises. Based on all the facts and evidence

discussed above and as contained in the 2004 Motions, the Trustee seeks the investigative tools afforded by Rule 2004 to further establish the true ownership of assets and to explore other potential assets about which the Trustee does not yet have knowledge.

15. The Trustee requests that, in furtherance of his examinations, the Court direct the Examinees to provide documentation to the Trustee's counsel, as requested in the forms annexed hereto3 and made a part hereof (the "Proposed Subpoenas"), within fourteen (14) days of the service of a subpoena, substantially similar in form and substance to the Proposed Subpoenas, or such other time as agreed upon by the Trustee. These requests seek documents consisting of, among other things, the Examinees' communications with the Debtor regarding his financial condition, asset transfers, and corporate governance issues. The requests also seek the Examinees' internal files and correspondence on these same topics.

16. The type of discovery that the Trustee will obtain from Examinees is well within the scope of Bankruptcy Rule 2004. Bankruptcy courts routinely provide for Rule 2004 discovery against professional firms when the discovery may identify and aid the recovery of assets for the benefit of the estate and creditors. *See, e.g., In re Bame,* 251 B.R. 367 (Bankr. D. Minn. 2000); *In re Horvath*, No. 13-34137, 2015 WL 2195060 (Bankr. N.D. Ohio May 7, 2015) (approving discovery related to claims on schedule of assets permissible from individual debtor where obtaining such discovery might increase the value of the debtor's estate).

17. The Trustee submits that the facts set forth above constitute sufficient cause for the Court to order the production of documents pursuant to Bankruptcy Rule 2004 from the

3 Included in Exhibit B is an index of Proposed Subpoenas that would be served on the Examinees if this Motion is granted. The Trustee also attaches hereto as **Exhibits C-1 to C-11** the individualized Proposed Subpoenas, including the topics for discovery directed to each Examinee, which are substantially similar in form and substance.

Examinees. Particularly considering the pattern of obstruction by the Debtor and certain of his family members and associates, seeking discovery from other parties, including the Examinees, is an essential investigative tool in identifying and recovering estate property. Indeed, documents in the possession of third parties like the Examinees have been among the most useful of those obtained in the Trustee's investigation to date.4

18. Authorization of this Application is critical for the Trustee to fulfill the duties contemplated in the Trustee Order effectively, including specifically his mandate to "locate the Debtor's assets for the benefit of creditors and the estate" and "investigate the Debtor's assets, liabilities, and financial affairs." (*See* Trustee Order at 15-16, 18).

19. No party in interest, including the Debtor, shall suffer undue prejudice upon the granting of the relief sought in this Application.

## **NO PRIOR REQUEST**

20. No prior application for the relief requested herein has been made. The Trustee filed the prior 2004 Motions however, those prior motions did not request to take discovery from the Examinees at issue here.

## **OBJECTION DEADLINE**

21. The deadline to object to this Application is April 1, 2025, and in the absence of a timely filed objection, the Proposed Order may enter without further notice and hearing.

*[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]*

4 The Trustee also requests authority to serve the Proposed Subpoenas on affiliates or subsidiaries of the Examinees if in the course of the Trustee's investigation it is determined that such affiliates and subsidiaries of the Examinees are the parties in control of documents relating to the Examinees that are relevant to the Trustee's investigation.

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WHEREFORE, the Trustee respectfully requests that the Court grant this Application and enter the Proposed Order, pursuant to Fed. R. Bankr. P. 2004(a), directing the examination of the Examinees, and directing the production of certain documents as set forth in the Requests for Production of Documents attached to the Proposed Subpoenas, and for such other and further relief as the Court may deem just and proper.

Dated: March 25, 2025 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

By: */s/ Kari A. Mitchell*

Kari A. Mitchell (ct31578) Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2884 kmitchell@npmlaw.com dskalka@npmlaw.com plinsey@npmlaw.com

*Counsel for the Chapter 11 Trustee*

# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|-------------|-------------------------| | In re: | : : | Chapter 11 | | 1 HO WAN KWOK, et al., | : : | Case No. 22-50073 (JAM) | | Debtors. | : : : | (Jointly Administered) | | ----------------------------------------------------------- | x | |

## **NOTICE OF OBJECTION DEADLINE**

Luc Despins, as the appointed Chapter 11 Trustee to the Debtor's Estate (the "Applicant"), has filed an Application for Rule 2004 Examination of certain corporate entities, individuals, and banking and financial institutions identified in **Exhibit B** (the "Rule 2004 Examination") with the U.S. Bankruptcy Court for the District of Connecticut. Notice is hereby given that any objection or response to the Rule 2004 Examination must be filed with the Court no later than April 1, 2025, in accordance with Fed. R. Bankr. P. 2002(a) and 9014 and Local Bankr. R. 2004-1(c). In the absence of a timely filed objection, the proposed order regarding the Rule 2004 Examination may enter without further notice and hearing, see 11 U.S.C. section 102(1).

[*REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK*.]

Dated: March 25, 2025 LUC A. DESPINS, New Haven, Connecticut CHAPTER 11 TRUSTEE

By: */s/ Kari A. Mitchell*

*Counsel for the Chapter 11 Trustee*

# **Exhibit A**

**Proposed Order**

| Case 22-50073 | Doc 4252 | Filed 03/25/25 | Entered 03/25/25 15:34:28 | Page 14 of | |---------------|----------|----------------|---------------------------|------------| | | | 208 | | |

# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|-------------|-------------------------| | In re: | : : | Chapter 11 | | 1 HO WAN KWOK, et al., | : : : | Case No. 22-50073 (JAM) | | Debtors. | : : | (Jointly Administered) | | ----------------------------------------------------------- | x | |

# **[PROPOSED] ORDER GRANTING NINETEENTH SUPPLEMENTAL OMNIBUS MOTION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER UNDER BANKRUPTCY RULE 2004 AND LOCAL RULE 2004-1 AUTHORIZING DISCOVERY WITH RESPECT TO ADDITIONAL RELEVANT BANKS, HOSPITALITY COMPANIES, AND ADDITIONAL ENTITIES ASSOCIATED WITH AND/OR DOING BUSINESS WITH DEBTOR AND DEBTOR-RELATED PERSONS**

Upon consideration of the Application seeking an order authorizing a Federal Rule of Bankruptcy Procedure 2004 examination of the Examinees listed on Exhibit B thereto (the "Application", ECF No. \_\_\_\_), filed by Luc Despins, as the appointed Chapter 11 Trustee to the Debtor's estate (the "Applicant"), after notice and a hearing, see 11 U.S.C. § 102(1), it appearing that cause exists to grant the requested relief as conditioned hereafter; it is hereby

**ORDERED**: The Rule 2004 Motion is granted as set forth below.

**ORDERED**: Neubert, Pepe & Monteith, P.C., as counsel for the Trustee, is hereby authorized to sign Subpoenas in a form substantially similar to the Subpoenas attached to the Rule 2004 Motion as Exhibits C-1 to C-11 and to serve the Subpoenas, along with a copy of this Order, in accordance with Bankruptcy Rule 2004 requiring examination and the production of documents by the Examinees listed on Exhibit B to the Application.

**ORDERED**: Subject to any rights under the Federal Rules of Bankruptcy Procedure, the Federal Rules of Civil Procedure, and applicable Local Rules, and unless otherwise ordered by the Court, the Examinees are hereby directed to produce all documents within 14 days of the service

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 15 of 208

of the Subpoena, or such other time as agreed upon by the Trustee. To the extent an Examinee does not produce any documents requested in the Subpoena on the basis of some privilege, the Examinee is hereby directed to produce to the Trustee a privilege log that comports with Fed. R. Civ. P. 45(e)(2), made applicable by Fed. R. Bankr. P. 9016, and D. Conn. L. Civ. R. 26(e), within 14 days of service of the Subpoena, or such other time as agreed upon by the Trustee.

**ORDERED**: The Examinees are hereby directed to ensure that all documents and other information, including without limitation in any electronic format, requested in the Subpoenas or otherwise relevant to the Debtor, his business, assets, liabilities, financial condition, or this Chapter 11 case, are properly maintained, are available for production, inspection and copying, and are not destroyed.

**ORDERED**: Neubert, Pepe & Monteith, P.C., as counsel for the Trustee, is hereby authorized, without further order of this Court, to take the testimony of one or more representatives of any Examinee listed on Exhibit B to the Application by examination under Bankruptcy Rule 2004 either at the offices of Neubert, Pepe & Monteith, 195 Church Street, 13th Floor, New Haven, CT 06510, at the offices of Paul Hastings LLP, 200 Park Avenue, New York, NY 10166, or at such other place that is mutually acceptable to the parties, on a date acceptable to the Trustee, which, at the election of the Trustee, shall be not less than 14 calendar days after the production of documents by the proposed examinee in compliance with the Subpoena and this Order pursuant to Bankruptcy Rule 2004, and such examination shall continue from day to day until completed.

Dated: \_\_\_\_\_\_\_\_\_\_\_, 2025

Julie A. Manning, United States Bankruptcy Judge

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

# **Exhibit B**

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| Discovery Party | Address | Subpoena Index | |--------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|----------------| | Bankwell Bank | 2704 Dixwell Avenue Hamden, CT 06518 | Exhibit C-1 | | Avidia Bank | Principal Office 42 Main Street Hudson, MA 01749 | Exhibit C-2 | | Uber Technologies, Inc. | Registered Agent The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 | Exhibit C-3 | | Marriot International, Inc. | Registered Agent Corporation Service Company Goodwin Square 225 Asylum Street, 20th Floor Hartford, CT 06103 | Exhibit C-4 | | Wyndham Hotels & Resorts | Principal Office 22 Sylvan Way Parsippany, NJ 07054 | Exhibit C-5 | | Choice Hotels International, Inc. | Resident Agent The United States Corporation Company 7 St. Paul St., Ste. 820 Baltimore, MD 21202 | Exhibit C-6 | | Joseph Rocco | 50 Wrights Mill Road Armonk, NY 10504 c/o Antoinette Violi, Esq. 78 East Putnam Avenue Cos Cob, CT 06807 | Exhibit C-7 |

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| Discovery Party | Address | Subpoena Index | |---------------------|-----------------------------------------------------|----------------| | Michael Rocco, Jr. | 627 North Street | Exhibit C-8 | | | Greenwich, CT 06830 | | | | c/o Antoinette Violi, Esq. | | | | 78 East Putnam Avenue | | | | Cos Cob, CT 06807 | | | Frank Rocco | 55 Wrights Mill Road | Exhibit C-9 | | | Armonk, NY 10504 | | | | | | | | c/o Antoinette Violi, Esq. 78 East Putnam Avenue | | | | Cos Cob, CT 06807 | | | The Royale | 188 East 64th Street | Exhibit C-10 | | Condominium, By its | New York, NY 10065 | | | Board of Managers | | | | | | | | | | | | Barclays PLC | 745 Seventh Avenue | Exhibit C-11 | | | New York, NY 10019 | | | | | | | | | | | | | |

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# Exhibit C-1

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 20 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

**SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Bankwell Bank**

(*Name of person to whom the subpoena is directed*)

*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

The following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

If this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

Software Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 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).

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \$ .

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.

#### *(2) Command to Produce Materials or Permit Inspection.*

*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.

*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.

*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.

#### *(2) Claiming Privilege or Protection.*

*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and

(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.

*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.

**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

1. Unless otherwise indicated, the requests for documents set forth below, (the "Requests," and each, a "Request"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.

2. Electronically stored information must be produced in accordance with the

following instructions:

- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file. - b. Image Load File - a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and

name of the native file. The native file must be named after the FIRSTBATES.

- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun. - c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level. - d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named "NATIVE" directories, separate from images directories. - e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file. - f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| Field Name | Sample Data | Description | |--------------|--------------------------|----------------------------------------------------------------------------------------------| | FIRSTBATES | EDC0000001 | First Bates number of native file document/email | | LASTBATES | EDC0000001 | Last Bates number of native file document/email **The LASTBATES field should be populated | | | | for single page | | ATTACHRANGE | EDC0000001 - | Bates number of the first page of the parent | | | EDC0000015 | document to the Bates number of the last page of | | | | the last attachment "child" document | | BEGATTACH | EDC0000001 | First Bates number of attachment range | | ENDATTACH | EDC0000015 | Last Bates number of attachment range | | CUSTODIAN | Smith, John | Email: Mailbox where the email resided | | | | Native: Name of the individual or department | | | | from whose files the document originated | | FROM | John Smith | Email: Sender | | | | Native: Author(s) of document | | | | **semi-colon should be used to separate | | | | multiple entries | | TO | Coffman, Janice; LeeW | Recipient(s) | | | [mailto:LeeW@MSN.com] | **semi-colon should be used to separate multiple | | | | entries | | CC | Frank Thompson [mailto: | Carbon copy recipient(s) | | | frank_Thompson@cdt.com] | **semi-colon should be used to separate | | | | multiple entries | | BCC | John Cain | Blind carbon copy recipient(s) | | | | **semi-colon should be used to separate | | | | multiple entries | | SUBJECT | Board Meeting Minutes | Email: Subject line of the email Native: Title | | | | of document (if available) | | FILE_NAME | BoardMeetingMinutes.docx | Native: Name of the original native file, | | | | including extension | | DATE_SENT | 10/12/2010 | Email: Date the email was sent | | | | Native: (empty) | | TIME_SENT/ | 07:05 PM GMT | Email: Time the email was sent/ Time zone in | | TIME_ZONE | | which the emails were standardized | | TIME_ZONE | GMT | The time zone in which the emails were | | | | standardized during conversion. | | LINK | EDC0000001.msg | Hyperlink to the email or native file document | | | | **The linked file must be named per the | | | | FIRSTBATES number | | FILE_EXTEN | MSG | The file type extension | | | | representing | | | | the Email or | | AUTHOR | John Smith | Email: (empty) | | | | Native: Author of the document | | DATE_CREATED | 10/10/2010 | Email: (empty) | | | | Native: Date the document was created |

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | | | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 27 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.

7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.

8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 28 of 208

such Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.

9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.

10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the subpoena.

11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

16. The terms (a) "and" and "or" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) "each" and "any" shall be deemed to include and encompass the words "every" and "all."

## **III. DEFINITIONS**

The definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:

1. "You" or "Your" or "Yourself" means and refers, to Bankwell Bank, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

2. "Debtor" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 30 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

5. "Debtor's Purported Wife" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

7. "2004 Discovery Targets" means, individually and collectively, the Debtor, the Debtor's Family, 17 Miles, LLC, 5780 Saguaro LLC, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), China Golden Spring Group (Hong Kong) Ltd., Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding "Ivan" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion (CA), G Fashion, G Fashion Hold Co. A. Limited, G Fashion Hold Co. B. Limited, G Fashion Media Group Inc., G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 31 of 208

LLC, G Club US Operations Inc., G Club US Operations LLC, G Club, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GF Italy, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya Currency Clearing Pty. Ltd., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan "Irene" Feng, Limarie Reyes, Lihong "Sara" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next Tycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, Omicron Neutraceutical LLC, O.S.C. Orbit Service Company, LLC, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer,

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 32 of 208

Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, Zhouer "Joe" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, Shin Hee-Seup a/k/a Hee Seup Shin, River Valley Operations LLC, Fiesta Investment Ltd., Fiesta Property Developments Ltd., Medical Supply System International LLC, New Smoke LLC, Mountains of Spices, LLC, Rainbow Gifts Inc., Santel LLC, Davy & Tony International Limited, Love Miles for Zisun Inc., Himalaya Boston Mayflower LLC, Top California Beach Corporation, Golden Eagle Ventures, LLC, Whole Alpha Trading LLC, and Art Operation LLC.

8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

- 10. "Any" and "all" and "each" mean "each and every." - 11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 33 of 208

14. "Document" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

15. "Person(s)" means an individual, corporation, proprietorship, partnership, association, or any other Entity. "Person" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.

16. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 34 of 208

business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.

17. "Regarding" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.

18. "Relating to," "relate(s) to" or "related to," when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.

19. "Communication(s)" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 35 of 208

helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.

#### **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.

2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.

3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.

4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.

5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 36 of 208

6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.

7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.

8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the S.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 37 of 208

# Exhibit C-2

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 38 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Avidia Bank**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 45 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 46 of 208

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers, to Avidia Bank, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 48 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 49 of 208

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 50 of 208

8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

- 10. "Any" and "all" and "each" mean "each and every." - 11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 51 of 208

16. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 52 of 208

business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 53 of 208

helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.

#### **IV. DOCUMENTS TO BE PRODUCED**

5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 54 of 208

6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 55 of 208

# Exhibit C-3

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 56 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Uber Technologies, Inc.**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | | | | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 63 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 64 of 208

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 65 of 208

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers, to Uber Technologies, Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 66 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 67 of 208

Fashion Hold Co. B. Limited, G Fashion Media Group Inc., G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Club, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GF Italy, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya Currency Clearing Pty. Ltd., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan "Irene" Feng, Limarie Reyes, Lihong "Sara" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 68 of 208

MOS Himalaya LLC, Next Tycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, Omicron Neutraceutical LLC, O.S.C. Orbit Service Company, LLC, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, Zhouer "Joe" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, Shin Hee-Seup a/k/a Hee Seup Shin, River Valley Operations LLC, Fiesta Investment Ltd., Fiesta Property Developments Ltd., Medical Supply System International LLC, New Smoke LLC, Mountains of Spices, LLC, Rainbow Gifts Inc., Santel LLC, Davy & Tony International Limited, Love Miles for Zisun Inc., Himalaya Boston Mayflower LLC, Top California Beach Corporation, Golden Eagle Ventures, LLC, Whole Alpha Trading LLC, and Art Operation LLC.

8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 69 of 208

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 70 of 208

16. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 71 of 208

20. "Asset(s)" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents related to the 2004 Discovery Targets including, without limitation: email addresses, phone numbers, partial credit card numbers, credit card zip codes, other payment instruments, government identification image (if available), trip/delivery information (including but not limited to amount charged, pickup and dropoff lat/long, and rider display name), billing transaction history, rider profile picture, and non-content records of communications between rider/driver.

2. All Documents related to any Communications between you and the 2004 Discovery Targets including but not limited to recordings of customer support calls, and other customer support communications.

3. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, including but not limited to authorized users of the account, maintenance of the account, dates of account creations, account status, and IP addresses.

4. All Documents related to any Transfers between You and any 2004 Discovery Target.

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 72 of 208

# Exhibit C-4

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 73 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

## **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Marriot International, Inc.**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 80 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 81 of 208

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 82 of 208

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to **Marriot International, Inc.**, together with all of its affiliates, subsidiaries, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 83 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

7. "Asset(s)" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.

8. "Associated Individuals" means, individually and collectively, the Debtor, the Debtor's Family, 17 Miles, LLC, 5780 Saguaro LLC, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 84 of 208

Li), China Golden Spring Group (Hong Kong) Ltd., Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding "Ivan" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion (CA), G Fashion, G Fashion Hold Co. A. Limited, G Fashion Hold Co. B. Limited, G Fashion Media Group Inc., G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Club, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GF Italy, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya Currency Clearing Pty. Ltd., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 85 of 208

Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan "Irene" Feng, Limarie Reyes, Lihong "Sara" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next Tycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, Omicron Neutraceutical LLC, O.S.C. Orbit Service Company, LLC, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, Zhouer "Joe" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, Shin Hee-Seup a/k/a Hee Seup Shin, River Valley Operations LLC, Fiesta Investment Ltd., Fiesta Property Developments Ltd., Medical Supply System International LLC, New Smoke LLC, Mountains of Spices, LLC, Rainbow Gifts Inc., Santel LLC, Davy & Tony International Limited, Love Miles for Zisun Inc., Himalaya Boston Mayflower LLC, Top California Beach Corporation, Golden Eagle Ventures, LLC, Whole Alpha Trading LLC, and Art Operation LLC.

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 86 of 208

10. "Any" and "all" and "each" mean "each and every."

11. "Communication(s)" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.

12. "Document" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 87 of 208

tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

13. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.

14. "Each" and "every" mean "each and every."

15. "Including" or any variant thereof means "including without limitation."

16. "Person(s)" means an individual, corporation, proprietorship, partnership, association, or any other Entity. "Person" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.

19. "Third Party" means a Person or Entity other than Yourself.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 88 of 208

20. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents and Communications related to any Transfers made by Associated Individuals, including, without limitation, the Debtor or the Debtor's Family, and further including, without limitation, Qiang Guo, *a/k/a* Mileson Guo, to You, including, without limitation, any hotels or other entities that are part of, associated with, or affiliated with You.

2. All Documents and Communications related to the use of hotels by and/or the provision of hospitality or related services to Associated Persons, including, without limitation, the Debtor or the Debtor's Family, and further including, without limitation, Qiang Guo, *a/k/a* Mileson Guo, with respect to You, including, without limitation, hotels or other entities that are part of, associated with, or affiliated with You.

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 89 of 208

# Exhibit C-5

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 90 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

**SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Wyndham Hotels & Resorts**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 97 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 98 of 208

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 99 of 208

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to **Wyndham Hotels & Resorts**, together with all of its affiliates, subsidiaries, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 100 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 101 of 208

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 102 of 208

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 103 of 208

10. "Any" and "all" and "each" mean "each and every."

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 104 of 208

14. "Each" and "every" mean "each and every."

15. "Including" or any variant thereof means "including without limitation."

19. "Third Party" means a Person or Entity other than Yourself.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 105 of 208

20. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 106 of 208

# Exhibit C-6

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 107 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

## **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Choice Hotels International, Inc.**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| Field Name | Sample Data | Description | |--------------|--------------------------|--------------------------------------------------| | FIRSTBATES | EDC0000001 | First Bates number of native file document/email | | LASTBATES | EDC0000001 | Last Bates number of native file document/email | | | | **The LASTBATES field should be populated | | | | for single page | | ATTACHRANGE | EDC0000001 - | Bates number of the first page of the parent | | | EDC0000015 | document to the Bates number of the last page of | | | | the last attachment "child" document | | BEGATTACH | EDC0000001 | First Bates number of attachment range | | ENDATTACH | EDC0000015 | Last Bates number of attachment range | | CUSTODIAN | Smith, John | Email: Mailbox where the email resided | | | | Native: Name of the individual or department | | | | from whose files the document originated | | FROM | John Smith | Email: Sender | | | | Native: Author(s) of document | | | | **semi-colon should be used to separate | | | | multiple entries | | TO | Coffman, Janice; LeeW | Recipient(s) | | | [mailto:LeeW@MSN.com] | **semi-colon should be used to separate multiple | | | | entries | | CC | Frank Thompson [mailto: | Carbon copy recipient(s) | | | frank_Thompson@cdt.com] | **semi-colon should be used to separate | | | | multiple entries | | BCC | John Cain | Blind carbon copy recipient(s) | | | | **semi-colon should be used to separate | | | | multiple entries | | SUBJECT | Board Meeting Minutes | Email: Subject line of the email Native: Title | | | | of document (if available) | | FILE_NAME | BoardMeetingMinutes.docx | Native: Name of the original native file, | | | | including extension | | DATE_SENT | 10/12/2010 | Email: Date the email was sent | | | | Native: (empty) | | TIME_SENT/ | 07:05 PM GMT | Email: Time the email was sent/ Time zone in | | TIME_ZONE | | which the emails were standardized | | TIME_ZONE | GMT | The time zone in which the emails were | | | | standardized during conversion. | | LINK | EDC0000001.msg | Hyperlink to the email or native file document | | | | **The linked file must be named per the | | | | FIRSTBATES number | | FILE_EXTEN | MSG | The file type extension | | | | representing | | | | the Email or | | AUTHOR | John Smith | Email: (empty) | | | | Native: Author of the document | | DATE_CREATED | 10/10/2010 | Email: (empty) | | | | Native: Date the document was created |

# Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 113 of 208

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 114 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 115 of 208

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 116 of 208

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

#### **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

#### **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to **Choice Hotels International, Inc.**, together with all of its affiliates, subsidiaries, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 117 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 118 of 208

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 119 of 208

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 120 of 208

10. "Any" and "all" and "each" mean "each and every."

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 121 of 208

14. "Each" and "every" mean "each and every."

15. "Including" or any variant thereof means "including without limitation."

19. "Third Party" means a Person or Entity other than Yourself.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 122 of 208

20. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 123 of 208

# Exhibit C-7

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 124 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

## **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Joseph Rocco**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 130 of 208

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 131 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 132 of 208

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 133 of 208

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

#### **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

#### **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to **Joseph Rocco**, together with all representatives and/or anyone acting on his behalf.

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 134 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

8. "2004 Discovery Targets" means, individually and collectively, the Debtor, the Debtor's Family, 17 Miles, LLC, 5780 Saguaro LLC, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), China Golden Spring Group (Hong Kong) Ltd., Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding "Ivan" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA,

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 135 of 208

Inc., Gnews Media Group Inc., G Fashion (CA), G Fashion, G Fashion Hold Co. A. Limited, G Fashion Hold Co. B. Limited, G Fashion Media Group Inc., G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Club, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GF Italy, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya Currency Clearing Pty. Ltd., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan "Irene" Feng, Limarie Reyes, Lihong "Sara" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 136 of 208

Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next Tycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, Omicron Neutraceutical LLC, O.S.C. Orbit Service Company, LLC, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, Zhouer "Joe" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, Shin Hee-Seup a/k/a Hee Seup Shin, River Valley Operations LLC, Fiesta Investment Ltd., Fiesta Property Developments Ltd., Medical Supply System International LLC, New Smoke LLC, Mountains of Spices, LLC, Rainbow Gifts Inc., Santel LLC, Davy & Tony International Limited, Love Miles for Zisun Inc., Himalaya Boston Mayflower LLC, Top California Beach Corporation, Golden Eagle Ventures, LLC, Whole Alpha Trading LLC, and Art Operation LLC, including, without limitation, the agents or representatives of the foregoing.

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Communication(s)" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise).

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 137 of 208

Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.

### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 138 of 208

kind not found on the original documents or that are otherwise not identical to the original documents.

14. "Each" and "every" mean "each and every."

15. "Including" or any variant thereof means "including without limitation."

19. "Third Party" means a Person or Entity other than Yourself.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 139 of 208

20. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

21. "1 Loch Lane" shall mean that real property (including all improvements and other Assets located thereon) commonly known as 1 Loch Lane, Greenwich, Connecticut.

#### **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents related to the lease, sale, or use of 1 Loch Lane, from January 1, 2024 through and including the date of Your response hereto, whether contemplated or consummated.

2. All Documents related to any Transfers related to 1 Loch Lane, from January 1, 2024 through and including the date of Your response hereto.

3. All Documents related to any Transfers by, on behalf of, or for the benefit of any of the 2004 Discovery Targets, including, without limitation, the Debtor's Family, further including, without limitation, the Debtor's Purported Wife or the Debtor's Daughter.

4. All Documents related to any of the 2004 Discovery Targets, including, without limitation, the Debtor's Family, further including, without limitation, the Debtor's Purported Wife or the Debtor's Daughter.

5. All Communications related to 1 Loch Lane from January 1, 2024 through and including the date of Your response hereto.

6. All Communications with or related to the 2004 Discovery Targets, including, without limitation, the Debtor's Family, further including, without limitation, the Debtor's Purported Wife or the Debtor's Daughter.

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 140 of 208

# Exhibit C-8

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 141 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Michael Rocco, Jr.**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 147 of 208

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 148 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 149 of 208

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 150 of 208

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

#### **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

#### **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to **Michael Rocco, Jr.**, together with all representatives and/or anyone acting on his behalf.

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 151 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 152 of 208

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 153 of 208

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Communication(s)" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise).

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 154 of 208

### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 155 of 208

kind not found on the original documents or that are otherwise not identical to the original documents.

14. "Each" and "every" mean "each and every."

15. "Including" or any variant thereof means "including without limitation."

19. "Third Party" means a Person or Entity other than Yourself.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 156 of 208

20. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

21. "1 Loch Lane" shall mean that real property (including all improvements and other Assets located thereon) commonly known as 1 Loch Lane, Greenwich, Connecticut.

#### **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents related to the lease, sale, or use of 1 Loch Lane, from January 1, 2024 through and including the date of Your response hereto, whether contemplated or consummated.

2. All Documents related to any Transfers related to 1 Loch Lane, from January 1, 2024 through and including the date of Your response hereto.

5. All Communications related to 1 Loch Lane from January 1, 2024 through and including the date of Your response hereto.

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 157 of 208

# Exhibit C-9

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 158 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Frank Rocco**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 164 of 208

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 165 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 166 of 208

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 167 of 208

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

#### **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

#### **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to **Frank Rocco**, together with all representatives and/or anyone acting on his behalf.

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 168 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 169 of 208

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 170 of 208

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Communication(s)" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise).

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 171 of 208

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 172 of 208

kind not found on the original documents or that are otherwise not identical to the original documents.

14. "Each" and "every" mean "each and every."

15. "Including" or any variant thereof means "including without limitation."

19. "Third Party" means a Person or Entity other than Yourself.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 173 of 208

20. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

21. "1 Loch Lane" shall mean that real property (including all improvements and other Assets located thereon) commonly known as 1 Loch Lane, Greenwich, Connecticut.

#### **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents related to the lease, sale, or use of 1 Loch Lane, from January 1, 2024 through and including the date of Your response hereto, whether contemplated or consummated.

2. All Documents related to any Transfers related to 1 Loch Lane, from January 1, 2024 through and including the date of Your response hereto.

5. All Communications related to 1 Loch Lane from January 1, 2024 through and including the date of Your response hereto.

# Exhibit C-10

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 175 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

## To: **The Royale Condominium, By its Board Of Managers**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 180 of 208

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 181 of 208

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 182 of 208

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 183 of 208

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 184 of 208

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

#### **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

#### **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to **The Royale Condominium, By its Board of Managers**, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, management companies, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 185 of 208

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 186 of 208

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 187 of 208

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

#### Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 188 of 208

10. "Any" and "all" and "each" mean "each and every."

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 189 of 208

14. "Each" and "every" mean "each and every."

15. "Including" or any variant thereof means "including without limitation."

19. "Third Party" means a Person or Entity other than Yourself.

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 190 of 208

20. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

21. "Wang Condominium" shall mean that condominium unit commonly known as 188 East 64th Street, Unit 1601, New York, NY 10065.

#### **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents related to any purchase, lease, rental, or other transaction related to the Wang Condominium, whether contemplated or consummated.

2. All Documents related to any Transfers related to the Wang Condominium, including, without limitation, with respect to transactions involving the Wang Condominium or payment of condominium fees, maintenance fees, taxes, or any other costs or expenses related to the Wang Condominium.

3. All Documents related to any Transfers by the 2004 Discovery Targets related to You or the Wang Condominium.

4. All Communications by You with or related to any of the Wang Condominium or the 2004 Discovery Targets, including, without limitation, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang).

5. All Documents related to any agreements, applications, financial disclosures, or identification documents related to the Wang Condominium or the 2004 Discovery Targets, including, without limitation, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang).

Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 191 of 208

# Exhibit C-11

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 192 of

UNITED STATES BANKRUPTCY COURT 208

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Barclays PLC**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | n/a | n/a | | | |

The examination will be recorded by this method: n/a

#### **See Requests for Production of Documents, attached hereto. Production due within fourteen (14) days of service.**

Date:

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Kari A. Mitchell, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 kmitchell@npmlaw.com; (203) 781-2884**

#### **Notice to the person who issues or requests this subpoena**

#### **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

#### *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

#### *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 198 of 208

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

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including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

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12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

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14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

#### **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

#### **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers, to Barclays PLC, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

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3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

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8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

- 10. "Any" and "all" and "each" mean "each and every." - 11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

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16. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other

## Case 22-50073 Doc 4252 Filed 03/25/25 Entered 03/25/25 15:34:28 Page 206 of 208

business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.

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helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.

#### **IV. DOCUMENTS TO BE PRODUCED**

5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.

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6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.