Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #4347

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., :

Debtors.1 : :

: -------------------------------------------------------------- x MONTHLY FEE STATEMENT OF KROLL, LLC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM MARCH 1, 2025 THROUGH MARCH 31, 2025

In accordance with the Order Establishing Procedures for Interim Compensation and

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

2094] (the "Interim Compensation Order"),2 Kroll, LLC ("Kroll") hereby submits this monthly statement (the "Monthly Fee Statement") seeking compensation for services rendered and reimbursement of expenses incurred as forensic investigators to Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok, for the period from March 1, 2025 through and including March 31, 2025 (the "Fee Period"). By this Monthly Fee Statement, Kroll respectfully requests payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the Fee Period, in the amounts of \$48,665.40 and \$35,038.38, respectively.

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

2 Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Interim Compensation Order.

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

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

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

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

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

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

(holley.l.claiborn@usdoj.gov)); (iv) counsel for the Official Committee of Unsecured Creditors, Pullman & Comley, LLC, 850 Main Street, 8th Floor, PO Box 7006, Bridgeport, Connecticut 06601-7006 (Attn: Irve J. Goldman (igoldman@pullcom.com); and (v) counsel for Pacific Alliance Asia Opportunity Fund L.P., O'Melveny & Myers LLP, 7 Times Square, New York, New York 10036 (Attn: Peter Friedman (pfriedman@omm.com) and Stuart M. Sarnoff (ssarnoff@omm.com) (collectively, the "Notice Parties").

7. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Kroll (Attn: Allen Pfeiffer (allen.pfeiffer@kroll.com) and (ii) the Notice Parties by email no later than May 14, 2025 at 4:00 p.m. (prevailing Eastern Time) (the "Objection Deadline"), setting forth the nature of the objection and the specific amount of fees or expenses at issue.

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

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

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

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In re: :

HO WAN KWOK, et al.,1 : :

Debtors. :

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

Dated: April 23, 2025 By: /s/ G. Alexander Bongartz

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

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

Time Period: March 1-31, 2025.

Timekeeper Title Service Line Standard Discounted Total Total Fees

Parizek, Pam Managing Director Forensic Investigations \$ 890 \$ 712 3.9 \$

Barker, James Associate Managing Forensic Investigations \$ 710 \$ 639 20.5 \$

Lazarus, Jordan Senior Manager Forensic Investigations \$ 575 \$ 518 9.9 \$

Lomas, Adam Senior Manager Forensic Investigations \$ 575 \$ 518 52.1 \$

Pallas, Xavier Senior Manager Forensic Investigations \$ 575 \$ 518 6.5 \$

Levenson, Patrick Associate Manager Forensic Investigations \$ 420 \$ 378 10.8 \$

Spier, Tre Research Analyst Forensic Investigations \$ 245 \$ 221 24.6 \$

Total Hours and Fees:

SUMMARY OF COMPENSATION BY PROJECT CATEGORY

Time Period: March 1-31, 2025.

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

B110 Case Administration 4.2 \$ 2,615.90

B120 Asset Analysis and Recovery 104.1 \$ 47,212.10

B160 Fee/Employment Applications 4.7 \$ 2,587.85 B170 Fee/Employment Objections - \$ - B180 Avoidance Action Analysis 15.3 \$ 8,415.90 B181 Preference Analysis and Recovery Actions - \$ - B182 Post-Petition Transfers and Recovery Actions - \$ - Other Contested Matters (excl. B190 assumption/rejections motions) - \$ -

Time Period: March 1-31, 2025.

00001 General Debtor Representation 5.4 \$ 2,950.10 00002 Asset Recovery Investigation and Litigation 108.4 \$ 49,850.50 00003 HK USA Adversary Proceeding - \$ - 00004 Bravo Luck Adversary Proceeding - \$ - 00005 PAX Adversary Proceeding - \$ - 00006 SN Apartment Adversary Proceeding - \$ - 00007 Greenwich Land Adversary Proceeding - \$ - 00008 AIG Adversary Proceeding - \$ - 00009 Mei Guo Adversary Proceeding 10.6 \$ 5,485.50 00010 Interpleader Adversary Proceeding - \$ - 00011 HCHK Adversary Proceeding - \$ - 00012 Golden Spring Adversary Proceeding - \$ - 00013 Mahwah Adversary Proceeding - \$ -

00015 Lamp Capital Adversary Proceeding - \$ - 00016 G-Club Adversary Proceeding - \$ - 00017 Rule of Law Adversary Proceeding - \$ - 00018 UAE Asset Recovery Actions 3.9 \$ 2,545.65 00019 Leading Shine Adversary Proceeding - \$ -

Time Period: March 1-31, 2025.

Expense Category Matter ID Task Code Expense Amount

Database and Research Fees for \$ 2,351.17 March Asset Recovery Investigation and Litigation Asset Analysis and Recovery

(Investigative Research in UAE) Asset Recovery Investigation and Litigation Asset Analysis and Recovery Valid8 Charges General Debtor Representation Case Administration 140.40

Timekeeper Date Matter Task Narrative Hours Amount

and Recovery Review and analysis of 2.4 \$ 1,242.00

Administration transactions. Call with A. Lomas, J. Lazarus, P. Parizek, I. Jones, Paul Hastings [L.

and NPM Law [P. Linsey] re:

Administration Call with A. Lomas, J. Lazarus, J. Barker, I. Jones, Paul Hastings [L.

and NPM Law [P. Linsey] re:

Lazarus, Jordan 3/3/2025 Asset Recovery

Administration Call with A. Lomas, J. Barker, P. Parizek, I. Jones, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song], and NPM Law [P. Linsey and K. Mitchell] re:

and Recovery Prepare summary schedules of activity on 2.9 \$ 1,500.75

and Recovery Correspondence with K. Mitchell and A. Lomas re:

and Recovery Meeting re:

transactions, with: Paul Hastings [L. Depsins, N. Bassett, D. Barron, and L. Song]; NPM Law [P.

I. Jones, J. Barker, and J. Lazarus. 1.0 \$ 517.50

and Recovery Conducted Relativity research to identify

defendants; reported draft findings in writing. 2.7 \$ 1,397.25

and Recovery Correspondence with K. Mitchell and A. Lomas re:

and Recovery Respond to inquiry from NPM Law [K.

Lazarus, Jordan 3/4/2025 Asset Recovery

Action Analysis Review correspondence from Kroll team re:

Timekeeper Date Matter Task Narrative Hours Amount

Action Analysis Respond to inquiry from NPM Law [P.

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

and Recovery Continued attention to summary

and Recovery Aggregate documents underlying

and Recovery Respond to inquiry from NPM Law [K.

Lazarus, Jordan 3/5/2025 Asset Recovery

and Recovery Review correspondence from Kroll team re:

Action Analysis Respond to inquiry from NPM Law [P.

and Recovery Review and analysis of certain bank

and Recovery Instructions to T. Spier re: analysis of

ongoing staff supervision. 0.8 \$ 414.00

Action Analysis Respond to inquiry from NPM Law [P. Linsey] re: postpetition transfers to 0.8 \$ 414.00

Action Analysis Respond to inquiry from NPM Law [P.

additional identified transfers to 0.3 \$ 155.25

Action Analysis Correspondence/email with X. Pallas

and Recovery Review of supplemental document

account/cards;

Action Analysis Conducted Relativity research to identify

defendants; reported draft findings in writing. 3.8 \$ 1,966.50

and Recovery Correspondence and coordination with J.

Action Analysis Correspondence/email with X. Pallas

Timekeeper Date Matter Task Narrative Hours Amount

Levenson, Patrick 3/6/2025 Asset Recovery

and Recovery attribution research. 0.5 \$ 189.00

Action Analysis Respond to inquiry from NPM Law [P. Linsey] re: support for specific transfers

and Recovery Review and analysis of certain bank

and Recovery Correspondence/email with P. Levenson and L. Despins re:

Lazarus, Jordan 3/6/2025 General Debtor

Applications Billing - Prepare February 2025 monthly

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

and Recovery Correspondence/email with R. Phelps re:

and Recovery Compiled documents with respect to

and Recovery Correspondence/email with P. Levenson and L. Despins re:

Action Analysis Correspondence/email with X. Pallas

Lazarus, Jordan 3/7/2025 General Debtor

Applications Billing - Prepare February 2025 monthly

and Recovery Continued compilation of bank records

Lazarus, Jordan 3/10/2025 Asset Recovery

and Recovery Analysis of all transfers to 0.3 \$ 155.25

and Recovery Respond to inquiry from Paul Hastings

and Recovery Respond to inquiry from NPM Law [P.

banks to add to next Rule 2004 motion. 0.8 \$ 414.00

Action Analysis Correspondence/email with E. Sutton re: 0.8 \$ 511.20 Lazarus, Jordan 3/10/2025 Asset Recovery

and Recovery Review correspondence with L. Despins and Kroll team re:

Timekeeper Date Matter Task Narrative Hours Amount

and Recovery Correspondence/email with R. Phelps re:

Action Analysis Respond to inquiry from Paul Hastings

and Recovery Review update re:

and Recovery Correspondence/email with I. Hamilton Sanchez re:

and Recovery Correspondence/email with L. Despins re:

and Recovery Internal team meeting discussion with P.

Lazarus, Jordan 3/11/2025 General Debtor

Applications Billing - Prepare February 2025 monthly

and Recovery Compose email to internal Kroll team re:

Levenson, Patrick 3/12/2025 Asset Recovery

and Recovery Internal Kroll team meeting re: matter update and proposed next steps with P. Parizek, J. Barker, J. Lazarus, and A.

and Recovery Internal Kroll team meeting re: matter update and proposed next steps with P. Parizek, J. Barker, J. Lazarus, and P.

and Recovery Internal Kroll team meeting re: matter update and proposed next steps with P. Parizek, P. Levenson, J. Lazarus, and A.

and Recovery Internal Kroll team meeting re: matter update and proposed next steps with J. Barker, P. Levenson, J. Lazarus, and A.

Lazarus, Jordan 3/12/2025 General Debtor

and Recovery Phone call with Kroll team [P. Parizek,

workstream updates and related matters. 0.7 \$ 362.25

and Recovery Correspondence/email with L. Song re:

and Recovery Review list of 0.1 \$ 71.20 Lazarus, Jordan 3/13/2025 General Debtor

Applications Billing - Prepare February 2025 monthly

and Recovery Prepare list of identified/suspected

Timekeeper Date Matter Task Narrative Hours Amount

and Recovery Review and analysis of certain bank

Administration Call with A. Lomas, J. Lazarus, P. Parizek, I. Jones, Paul Hastings [L.

Law [P. Linsey] re:

and Recovery Correspondence/email with A.Lomas re: 4.0 \$ 2,556.00

Administration Call with A. Lomas, J. Lazarus, J. Barker, I. Jones, Paul Hastings [L.

Law [P. Linsey] re:

Lazarus, Jordan 3/13/2025 Asset Recovery

and Recovery Correspondence with Kroll team re:

and Recovery Correspondence/email with I. Jones and

Lazarus, Jordan 3/13/2025 Asset Recovery

Administration Call with A. Lomas, J. Barker, P. Parizek, Paul Hastings [L. Despins, D. Barron, L. Song], and NPM Law [P. Linsey and K. Mitchell] re: 0.4 \$ 207.00

and Recovery Meeting re: litigation updates, possible

D. Barron, and L. Song]; NPM Law [P.

J. Barker, and J. Lazarus. 0.4 \$ 207.00

and Recovery Review and analysis of certain bank

Applications Review, revise February Fee Statement. 0.5 \$ 356.00

and Recovery Review update from I. Jones re:

and Recovery Review of document productions from

and Recovery Analysis of various bank statements 0.4 \$ 207.00

and Recovery Review documents/case materials from 1.2 \$ 766.80

Timekeeper Date Matter Task Narrative Hours Amount

Lomas, Adam 3/17/2025 Asset Recovery Asset Analysis Instructions to T. Spier re: review of new 0.2 \$ 103.50 Investigation and and Recovery bank document productions.

Lomas, Adam 3/17/2025 Asset Recovery Avoidance Incorporate 0.5 \$ 258.75 Investigation and Action Analysis transactions transactions into master Litigation transaction file for review/analysis. Parizek, Pam 3/17/2025 General Debtor Fee/Employment Review redactions to February Fee 0.3 \$ 213.60 Representation Applications Statement, approve for filing. Lomas, Adam 3/17/2025 Asset Recovery Asset Analysis Upload of bank statements into bank 0.4 \$ 207.00 Investigation and and Recovery statement analysis tool.

Levenson, Patrick 3/17/2025 Asset Recovery Asset Analysis Conducted

Investigation and and Recovery Targeted

discuss findings and strategy. Spier, Tre 3/18/2025 Asset Recovery Asset Analysis Review and analysis of 1.2 \$ 264.60 Investigation and and Recovery account transactions; related updates to Litigation master transaction file. Barker, James 3/18/2025 UAE Asset Asset Analysis Review documents/case materials from 0.6 \$ 383.40

Spier, Tre 3/18/2025 Asset Recovery Asset Analysis Review and analysis of 1.5 \$ 330.75 Investigation and and Recovery bank account transactions; Litigation related updates to master transaction file. Lazarus, Jordan 3/18/2025 UAE Asset Asset Analysis Review correspondence re: 0.1 \$ 51.75 Recovery Actions and Recovery next steps, and related matters. Parizek, Pam 3/18/2025 UAE Asset Asset Analysis Email exchange with Paul Hastings re: 0.1 \$ 71.20

re: same. Lomas, Adam 3/18/2025 Mei Guo Asset Analysis Update of schedules summarizing bank 2.2 \$ 1,138.50 Adversary and Recovery transaction activity for Proceeding compose related email to Paul Hastings [L. Song]. Lazarus, Jordan 3/18/2025 Asset Recovery Asset Analysis Review correspondence from K. Mitchell 0.2 \$ 103.50 Investigation and and Recovery re: account information request for Litigation and related matters.

Levenson, Patrick 3/18/2025 Asset Recovery Asset Analysis Conducted

Investigation and and Recovery Targeted

discuss findings and strategy. Lomas, Adam 3/18/2025 Mei Guo Asset Analysis Review of additional 1.8 \$ 931.50 Adversary and Recovery related analysis of Proceeding account transactions; related updates to master transaction file.

Lomas, Adam 3/18/2025 Asset Recovery Asset Analysis Respond to inquiry from NPM Law [K. 0.3 \$ 155.25

Litigation and Recovery Mitchell] re: known/suspected accounts

and Recovery Correspondence/email with L. Song re: 1.8 \$ 1,150.20 Litigation research.

re:

with J. Barker, I. Jones re: same.

and Recovery Updates to bank subpoena tracker; related document and transaction review. 1.8 \$ 931.50

Timekeeper Date Matter Task Narrative Hours Amount

Levenson, Patrick 3/19/2025 Asset Recovery

research;

discuss findings and strategy. 0.3 \$ 113.40

and Recovery Internal team meeting with P. Levenson re:

and Recovery Email exchange with Paul Hastings re: 0.1 \$ 71.20

and Recovery Telephone call with NPM Law [P. Linsey] re:

and Recovery Review documents/case materials from 0.8 \$ 511.20

and Recovery Revisions to schedules summarizing

and Recovery Meeting with Paul Hastings [L. Song] re:

and Recovery Respond to inquiry from Paul Hastings [L. Song] re: questions/comments re:

Lazarus, Jordan 3/24/2025 Asset Recovery

and Recovery Compilation of transfers to and supporting documentation;

Action Analysis Respond to inquiry from Paul Hastings

and Recovery Additional revisions to chart of bank account activity;

and Recovery Updates to bank subpoena tracker;

and account reconciliation. 3.8 \$ 1,966.50 Levenson, Patrick 3/25/2025 Asset Recovery

and Recovery Respond to inquiries from Paul Hastings

Timekeeper Date Matter Task Narrative Hours Amount

Levenson, Patrick 3/26/2025 Asset Recovery

and Recovery Updates to bank subpoena tracker;

and Recovery Upload of bank statements into bank

and Recovery Compose email to Paul Hastings and

and Recovery Compose email to NPM Law [K.

Levenson, Patrick 3/27/2025 Asset Recovery

and Recovery Correspondence/email with P. Parizek re:

updates to master transaction file. 0.4 \$ 207.00

and Recovery Review Rule 2004 subpoena tracker. 0.3 \$ 213.60 Levenson, Patrick 3/28/2025 Asset Recovery

and Recovery Correspondence/email P.Levenson re:

production; related update of inventory of

and P. Linsey] re: follow-up requests. 1.3 \$ 672.75 Lazarus, Jordan 3/31/2025 Asset Recovery

and Recovery Correspondence with L. Song and A.

and Recovery Respond to inquiry from Paul Hastings [L. Song] re: in schedule of transfers to 0.3 \$ 155.25

updates to master transaction file. 0.5 \$ 258.75

document production;

Timekeeper Date Matter Task Narrative Hours Amount

Action Analysis Respond to inquiry from Paul Hastings

document review and research. 0.9 \$ 465.75 Total Hours and Amount: 128.3 \$ 60,831.75