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case_no: "22-50073"
doc_number: 4811
doc_type: "NOTICE"
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# Guo Wengui / Miles Guo — bankruptcy case · NOTICE · ECF #4811



UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

x

In re:　:
:
Chapter 11

HO WAN KWOK, et al.,　:
Case No. 22-50073 (JAM)
:
Debtors.1　:
Jointly Administered

---------------------------------------------------------------　x
CHAPTER 11 TRUSTEE'S NOTICE OF FURTHER REVISED OUTLINE OF PROPOSED PRETRIAL PROCEDURES AND SCHEDULE FOR AVOIDANCE ACTION ADVERSARY PROCEEDINGS IN CONNECTION WITH NOVEMBER 3, 2025 CONTINUED HEARING

Luc A. Despins, in his capacity as Chapter 11 Trustee (the "Trustee") appointed in the chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok (the "Debtor"), hereby files his revised outline of proposed pretrial procedures and schedule for avoidance action adversary proceedings (the "Revised Outline"), based on the Court's comments at the hearing held in the Chapter 11 Case on October 27, 2025, and further feedback from avoidance action defendants. In respect to the foregoing, the Trustee respectfully states:

1. Since the October 27 hearing, among other things, the Trustee has conferred with representative counsel for certain avoidance action defendants (the "Joint Defendants") and reviewed a counterproposal outline filed by the Joint Defendants on October 29, 2025 [ECF No. 4791] (the "Joint Defendants' Outline").

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

2. In contemplation of the November 3, 2025 continued hearing, the Trustee attaches

his Revised Outline hereto as Exhibit A (in a clean form) and Exhibit B (in a redline form compared to the Joint Defendants' Outline).

3. While the Revised Outline reflects numerous language changes compared to the

Joint Defendants' Outline, the number of material issues separating the parties has narrowed

considerably, and now principally includes the following:

- The Trustee's Revised Outline provides for avoidance claims to be trial-ready by June 15, 2025, rather than by August 17, 2025 (as the Joint Defendants propose).
- The Revised Outline immediately lifts all (a) full and partial stays under ¶ 2(e) (i) and (ii) of the May 2, 2024 avoidance and mediation procedures order [ECF No. 3163] (the "May 2, 2024 Procedures Order") [2] and (b) mediation stays under ¶ 2(j)(iii) of the May 2, 2024 Procedures Order[3] ; and sets a December 15, 2025 answer deadline for claims that had previously been fully stayed.
- The Revised Outline has eliminated distinctions between "tranches" of defendants, which are no longer necessary given that stays under ¶¶ 2(e)(i) and 2(j)(iii) of the May 2, 2024 Procedures Order will be lifted, and the parties will follow a common discovery schedule.
- The Revised Outline incorporates the stay of constructive fraudulent transfer claims,[4] which the Joint Defendants' Proposal removed.
- The Trustee notes that the Joint Defendants removed the prohibition on motions under Fed. R. Civ. P. 12 and 56. [5] As a compromise, the Revised Outline requires parties wishing to prosecute motions under Fed. R. Civ. P. 12 and 56 to first obtain leave of the Court by filing short (maximum four-page) pre-motion requests.

2 These have been referred to as "3A" and "3B" stays, after the exhibit numbers to May 2, 2024 Procedures Order.

3 Under the Revised Outline, mediation of avoidance claims may continue on a voluntary basis. The Trustee is in the process of scheduling numerous mediation sessions with the assigned mediators and mediating defendants, and the Trustee looks forward to productive discussions.

4 The Trustee included this provision in his original outline based on the Court's comments at the October 21, 2025 hearing, at which the Court noted that adjudication of the Trustee's actual intent fraudulent transfer claims may dispense with the need to litigate constructive fraudulent transfer claims (filed in a small minority of actions).

5 Again, the Trustee included this provision based on the Court's comments at the October 21, 2025 hearing.

4. The Trustee is prepared to engage in further constructive discussions with avoidance defendants as to procedures for orderly and efficient avoidance litigation with due consideration of the parties' respective rights and interests.

[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]

Dated: October 30, 2025 LUC A. DESPINS, New Haven, Connecticut CHAPTER 11 TRUSTEE

By: /s/ Patrick R. Linsey Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.com

and

Nicholas A. Bassett *(*admitted pro hac vice) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

and

Douglass Barron (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6690 aviluft@paulhastings.com

Counsel for the Chapter 11 Trustee
UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

x

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

The foregoing, including all exhibits and attachments thereto, was filed on the date hereof in the Chapter 11 Case using the Court's case management/electronic case files system ("CM/ECF"). Notice of the foregoing was sent automatically via email by operation of CM/ECF on all parties appearing in the Chapter 11 Case that are eligible to receive electronic notice.

Dated: October 30, 2025 New Haven, Connecticut

> By: /s/ Patrick R. Linsey Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.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 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).
EXHIBIT A
(Revised Outline – Clean)
CHAPTER 11 TRUSTEE'S FURTHER COUNTERPROPOSAL TO JOINT DEFENDANTS' COUNTERPROPOSAL OF PROPOSED PRETRIAL PROCEDURES

Subject　General Description

Termination of Full and
Partial Stay and
Mediation Stay and
Establishment of Answer
Deadline for Stayed
Defendants　•
Any full and partial stays under ¶ 2(e) (i) and (ii) of the
May 2, 2024 avoidance and mediation procedures order
[ECF No. 3163] (the "May 2, 2024
Procedures Order")
and any mediation stays under ¶ 2(j)(iii) of the May 2,
2024 Procedures Order
shall terminate effective Nov.
10, 2024, provided, however, Mediation Proceedings
under the May 2, 2024 Procedures Order
may continue
upon
the
consent of parties to the
specific
mediation
and
the Mediator.
•
Any Defendant subject to claims that had been fully
stayed
under ¶¶
2(e)(i)
or 2(j)(iii)
of the May 2, 2024
Procedures Order, which stays were terminated by the
foregoing provision,
shall file an answer by Dec.
15,
2025, provided, however, if the Trustee has filed a
pending
motion for leave to amend his Avoidance
Complaint (a "Motion to Amend"), such Defendant
shall respond to the Motion to Amend (by objection or
by stipulation consenting to the amendment) by Dec.
15, 2025, and such Defendant shall
thereafter
file an
answer to the applicable complaint within 14 days of
the resolution (by Court Order or by stipulation) of the
Motion to Amend.
Stay of Constructive
Fraudulent Transfer
Claims　•
Litigation of any constructive fraudulent transfer claims
under section 548(a)(1)(A) of the Bankruptcy Code or
section 544(b) of the Bankruptcy Code and applicable
state law shall be stayed pending resolution of the
Trustee's actual intent fraudulent transfer claims or
further order of the Court.
Initial Disclosures　•
Initial Disclosures: Nov. 14, 2025,
provided, however,
as to Defendants subject to claims that had been fully
stayed
under ¶¶ 2(e)(i)
or 2(j)(iii)
of the May 2, 2024
Procedures Order, Dec. 15, 2025.
•
Trustee's obligations under Rule 26(a)(1)(A)(ii)
and as
to documents and evidentiary material under Rule
26(a)(1)(A)(iii)
will be satisfied by the population of
the Depository as set forth below.

Discovery Schedule　the Depository1
•
Trustee will populate
by Jan. 2, 2026
with Data Rooms
(with folders organized by source)
with documents related to
(i) all
alter ego
entities
involved
in
alleged
avoidable
transfers,
(ii)
any
appearing
Defendant,
and
(iii)
his
allegations
in
Avoidance Complaints asserting claims for
actual
intent
in respect to fraudulent transfer claims.
•
Initial RFPs
(issued by
the Trustee only);
Interrogatories
(for all parties); and RFAs (for all

parties) served
no later than:
Feb. 2, 2026
(+31)
Responses/Objections/Production3
•
: March 4, 2026
(+61)
•
Fact Discovery Deadline: June
1, 2026
(+150)
•
Avoidance Action trials begin: Week of June 15, 2026
(+164)

Mediation Provisions　•
Mediation
Proceedings
may
continue,
provided,
however, such proceedings
shall be terminable by either
party or by the Mediator upon written notice to the
Mediator and parties to
the specific
mediation.
Written Discovery　•
Defendant Interrogatories / Requests for Admission
o
Joint by Relevant Alter Ego: As
to issues regarding
alter ego entities involved in alleged
avoidable
transfers, all Defendants as to which
a
particular entity
is relevant
shall cooperate to issue no more than 15
joint
interrogatories
and

joint
requests
for
admission per entity.
o
Unique by Defendant: Each Defendant may issue up
to 10 interrogatories and 10 requests for admission
related to all other issues in their particular avoidance
action.
o
Any Defendant may seek an increase in the number of
written discovery requests by agreement or order of

1 Capitalized terms defined herein shall have the meaning set forth in the *Trustee's Second Revised Proposed Order Granting Chapter 11 Trustee's Motion for Entry of Order: (I) Supplementing, Amending, and Superseding (A) Order Directing Parties to Mediations, Appointing the Honorable James J. Tancredi as Mediator, and Amending Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings; and (B) Order Amending Order Directing Parties to Mediation, Appointing the Honorable James J. Tancredi as Mediator, and Amending Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings to Facilitate Consensual Pre-Litigation and Pre-Appearance Mediation; and (II) Approving Intervention of Appropriate Avoidance Defendants in Omnibus Alter Ego Actions as to Alter Ego Claims Against Specified Alter Ego Defendants*, which is available at Docket No. 4749 at Exhibit 1, and the exhibits thereto.

2 The +[number] is the number of days from population of the Depository.

3 The date to commence production, which may be rolling based on a schedule agreed to by the Trustee and that particular Defendant.

the Court.

•
Trustee's Interrogatories / Requests for Admission:
Maximum
of 25 interrogatories and 25 requests for admissions
for the
Trustee as against each Defendant, subject to potential increase
by agreement or order of the Court.
•
To the extent the Defendants believe relevant documents and
information are not available or readily identifiable in the
Depository, they shall serve a draft request for production
identifying such documents and information ("Draft RFP"),
and promptly meet and confer with the Trustee to determine
whether such documents and information exist in the Trustee's
possession, custody, or control, or are identifiable in the
Depository.
If the parties cannot resolve this issue, such
Defendant(s) may seek relief from the Court to order
production of the documents and information identified in the
Draft RFP into the Depository.
•
Production
of
documents
or
information
shall
neither
constitute nor evidence waiver of attorney-client privilege or
work product doctrine (i.e., reciprocal non-waiver provision).
Trustee's Document
Depository and Privilege
Logs　•
Trustee intends to produce responsive documents through
Depository, organized into Data Rooms (further organized by
producing party), subject to Trustee's reservations that vast
majority of documents were produced to Trustee by third
parties,
Trustee
makes
no
representations
as
to
accuracy/authenticity of such documents, and inclusion of
documents does not constitute admission or basis to argue
documents are relevant/admissible or constitute admission of
any fact.
•
Access to depository shall be limited to counsel and defendants
that have signed operative Protective Order/Addendum and
that are engaged in discovery with Trustee under this Order.
Protective Order/Addendum shall otherwise apply in all
discovery proceedings under this Order.
•
Trustee will serve in the initial instance a categorical privilege
log identifying, for each category of withheld documents, (a)
general parties to such documents/ communications (e.g., the
Debtor and his bankruptcy counsel at a particular law firm), (b)
the general subject matter of the withheld documents (e.g.,
legal advice related to bankruptcy filing), (c) the date range of
the documents in the category, and (d) the basis for the asserted
privilege (e.g., attorney-client privilege, work product, etc.).
The Trustee will meet and confer with defendants after
providing the categorical log if defendants believe further
information regarding privileges asserted by Trustee is
required as to any categories.
Deposition Discovery　•
Deposition discovery shall not commence prior to March
16,

(+73).

•
Trustee
and
Defendants
shall
cooperate
in
scheduling
depositions and ensuring
that Trustee and all
appearing
Defendants receive notice of any depositions.

•
Defendants shall share time and cooperate in posing questions
to witnesses and shall make their best efforts to not pose
duplicative questions.
•
Unless otherwise ordered by the Court, the parties shall depose
an individual or corporate representative one time, provided
that the time period specified in Rule 30(d)(1) may be enlarged
by agreement or order of the Court for good cause shown.
Expert Discovery　•
Any party that would like to disclose an expert under
Rule 26(a)(2)(A) shall provide such notice to the other
party by 60 days prior to the end of fact discovery. The
parties shall either stipulate to or seek an order of the
Court to set a schedule for the disclosures required under
Rule 26(a)(2)(B) and any expert-related discovery.
Trials / Intervention in
Omnibus Alter Ego
Actions　•
The Court shall hold a status conference approximately 21
days prior to the close of fact discovery for the purpose of
scheduling any pre-trial and trial proceedings.
•
The Trustee will file a motion requesting approval of similar
procedures in the Omnibus Alter Ego Actions so that claims
may be litigated and tried under Rule 42 to avoid duplication
of efforts and redundant proceedings.
•
Any trial proceedings shall be sequenced and/or consolidated
as appropriate, including under Rule 42 (as made applicable by
FRBP 7042), with priority given to adjudicating first claims
involving postpetition transfers and transfers involving entities
already established as the Debtor's alter egos by existing
judgments.
Pre-Motion Requests
as to
Certain Motions　•
A pre-motion request (a "Pre-Motion Request") (of no more
than four pages) shall be filed prior to filing
or adjudication of
any motion under FRCP 12 or 56, which Pre-Motion Request
shall set forth the basis for the proposed motion, to which any
adverse party may file a written response (a "Pre-Motion
Response") (of no more than four pages) within fourteen (14)
days. For the avoidance of doubt, this
requirement shall apply
to any
Defendant subject to claims that had been fully stayed
under ¶¶
2(e)(i)
or 2(j)(iii)
of the May 2, 2024 Procedures
Order
that filed a motion under FRCP 12 or 56 prior to or
during such stay.
•
After the filing of a Pre-Motion Request and any Pre-Motion

Response, the Court may rule on the papers as to whether the
requesting party may file the proposed motion or may schedule
a status conference to discuss the Pre-Motion Request.

Submission of Order and
Schedule　•
Trustee and Defendants shall submit a proposed order
incorporating these terms to the Court for each applicable
adversary proceeding.
EXHIBIT B
(Revised Outline – Redline)
CERTAINCHAPTER 11 TRUSTEE'S FURTHER COUNTERPROPOSAL TO JOINT DEFENDANTSDEFENDANTS' COUNTERPROPOSAL OF PROPOSED PRETRIAL PROCEDURES

Subject　General Description

Defendants Subject to　Aaron Mitchell; Aaron Mitchell; ACASS Canada Limited;
First Discovery　ACASS U.S.A. Inc.; Agora Lab, Inc.; Apple Inc.; Appsflyer
Litigation Schedule　Inc.; Bering Yachts, LLC; Berkeley Rowe Limited; Boardwalk
("First Tranche　Motor Imports, LLC; Boies Schiller Flexner LLP; Bourne in
Defendants")　Time Inc.; Brune Law PC; Debeche, Kamel; FFP (BVI)
Limited; Frankfurt Kurnit Klein & Selz PC; G4S Security
Systems (Hong Kong) Ltd.; Ganfer Shore Leeds & Zauderer,
LLP; Gunderson, Mark; Guo, Mei; Kdebeche, Inc.; LaBarbiera
Custom Homes, LLC; Law Office of Neil Sunkin; Lawall &
Mitchell LLC; Li, Weihu; Meta Platforms, Inc.; Miller
Motorcars, Inc.; Miller, Jason; ModSquad, Inc.; Mountains of
Spices, Inc.; Ngok, Hing Chi; Ogier; Petrillo Klein & Boxer
LLP; Putnam's Landscaping, LLC; Quinones Law PLLC;
Rovello Electric Inc.; Scarabaeus Wealth Management AG
n/k/a Prime Fund Solutions AG; Shujuan Craven nka Milne;
The Clear Creek Group, LLC; The Vision Group dba Bang &
Olufsen; V.X. Cerda & Associates P.A.; WA HF LLC; Walden
Macht Haran & Williams LLP; Warp & Weft Concepts Inc.;
Weddle Law PLLC; Wedlake Bell LLP; Yankwitt LLP;
Yongbing Zhang; Zeisler & Zeisler, P.C.; and ZYB &
Associates LLC
Defendants Remaining　3 Columbus Circle, LLC; Amazon Web Services, Inc.;
in Mediation　Amazon.com, Inc.; American Express Company & affiliate co
Proceedings ("Second　defendants; Anthem Health Plans, Inc.; Anthem HealthChoice
Tranche Defendants")1　Assurance, Inc. dba Empire Blue Cross Blue Shield; B&H Foto
& Electronics, Corp.; Cloudflare, Inc.; Cohen Howard LLP;
Direct Persuasion LLC; Eficens Systems LLC; Grocyber LLC;
Nardello & Co., LLC; Ohtzar Shlomo Solomon Treasure LLC;
On the Spot Home Improvement, Inc.; Phillips Nizer LLP;
Reach Manufacturing, LLC;
Reichard & Escalera LLC;
Sedgwick Realty Corp.; Teris-Phoenix, LLC;
Triple2 Digital

1The Joint Defendants have no objection to including every avoidance action adversary proceeding defendant in either the First Tranche or Second Tranche to allow those cases to proceed on the same track, which would address the Court's concern on completing the adjudication of all such actions in a timely manner; provided, however, that any mediations between the Second Tranche Defendants and the Trustee shall continue on the timeline provided herein. The Joint Defendants further recognize that certain avoidance actions may have been fully stayed, and, thus, defendants may not yet have had the opportunity to mediate the claims against them. Accordingly, those defendants might seek to be included in the Second Tranche so that they can have the opportunity to participate in mediation under the schedule proposed.

LLC; Troutman Pepper Hamilton Sanders LLP; Urban Legend
Media, Inc.; and Zeta Global Corp.

Answer / Initial
DisclosureTermination
of Full and Partial Stay
and Mediation Stay and
Establishment of Answer
Deadline for Stayed
Defendants　•
Motions to Amend Complaints
o
Any of the Trustee's pending motions to amend
complaints in the Defendants' (as defined below)
avoidance actions shall be heard by the Court on
or before [______ __, 2025] (each a "Motion to
Amend").
•
First Tranche Defendants:
o
Initial Disclosures: The later of (i) Nov. 14,
2025,
or (ii) 14 days after any order granting a
Motion to Amend.
o
Answers Due (if not already filed, and
superseding any answer deadline set by prior
stipulation): The later of (i) Nov. 14, 2025
or (ii)
14 days after any order granting a Motion to
Amend.
•
Second Tranche Defendants (as defined below):
o
Initial Disclosures: The later of (i) Jan.
14, 2026,
or (ii) 14 days after any order granting a Motion
to Amend.
•
Answers Due
(if not already filed, and superseding any
answer deadline set by prior stipulation): The later of (i)
Jan.
14, 2026,
or (ii) 14 days after any order granting a
Motion to Amend.Any full and partial stays under ¶ 2(e)
(i) and (ii) of the May 2, 2024 avoidance and mediation
procedures order [ECF No. 3163] (the "May 2, 2024
Procedures Order") and any mediation stays under ¶
2(j)(iii) of the May 2, 2024 Procedures Order
shall
terminate effective Nov.
10, 2024, provided, however,
Mediation Proceedings under the May 2, 2024
Procedures Order
may continue upon
the
consent of
parties to the
specific
mediation
and
the Mediator.
Any Defendant subject to claims that had been fully
stayed
under ¶¶
2(e)(i)
or 2(j)(iii)
of the May 2, 2024
Procedures Order, which stays were terminated by the
foregoing provision,
shall file an answer by Dec.
15,
2025, provided, however, if the Trustee has filed a
pending
motion for leave to amend his Avoidance
Complaint (a "Motion to Amend"), such Defendant shall
respond to the Motion to Amend (by objection or by
stipulation consenting to the amendment) by Dec.
15,
2025, and such Defendant shall
thereafter
file an answer

to the applicable complaint within 14 days of the
resolution (by Court Order or by stipulation) of the
Motion to Amend.
•
Trustee's obligations under Rule 26(a)(1)(A)(ii)
will be
satisfied by the population of the Depository as set forth
below.

Stay of Constructive
Fraudulent Transfer
Claims　•
Litigation of any constructive fraudulent transfer claims
under section 548(a)(1)(A) of the Bankruptcy Code or
section 544(b) of the Bankruptcy Code and applicable
state law shall be stayed pending resolution of the
Trustee's actual intent fraudulent transfer claims or
further order of the Court.
Initial Disclosures　•
Initial Disclosures: Nov. 14, 2025,
provided, however,
as to Defendants subject to claims that had been fully
stayed
under ¶¶ 2(e)(i)
or 2(j)(iii)
of the May 2, 2024
Procedures Order, Dec. 15, 2025.
•
Trustee's obligations under Rule 26(a)(1)(A)(ii)
and as
to documents and evidentiary material under Rule
26(a)(1)(A)(iii)
will be satisfied by the population of the
Depository as set forth below.
Discovery Schedule　•
Trustee populateswill populate
by Jan. 2, 2026
the
Depository2 with Data Rooms
for (i) all transferor entities
(with folders organized by source), which Data Rooms
will include)
with
documents related to
(i) all
alter ego
entities involved in alleged
avoidable transfers,
(ii) any
appearing Defendant,
and information supporting the
Trustee's claims under 11 U.S.C. § 549, and (ii(iii) his
allegations in Avoidance Complaints asserting claims for
actual
intent or constructivein respect to
fraudulent
transfer under the Bankruptcy Code and/or comparable

state avoidance statutes: January 2, 2026.
claims.

2 Capitalized terms defined herein shall have the meaning set forth in the *Trustee's Second Revised Proposed Order Granting Chapter 11 Trustee's Motion for Entry of Order: (I) Supplementing, Amending, and Superseding (A) Order Directing Parties to Mediations, Appointing the Honorable James J. Tancredi as Mediator, and Amending Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings; and (B) Order Amending Order Directing Parties to Mediation, Appointing the Honorable James J. Tancredi as Mediator, and Amending Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings to Facilitate Consensual Pre-Litigation and Pre-Appearance Mediation; and (II) Approving Intervention of Appropriate Avoidance Defendants in Omnibus Alter Ego Actions as to Alter Ego Claims Against Specified Alter Ego Defendants*, which is available at Docket No. 4749 at Exhibit 1, and the exhibits thereto.

3 The earliest date that Trustee has indicated the Depository can be available.

•
Initial RFPs
(forissued by
the Trustee only);
Interrogatories
(for all parties); and RFAs (for all

parties) served
no later than:
Feb. 162, 2026
(+4531)
Responses/Objections/Production5
•
: March 184, 2026
(+7561)
•
Fact Discovery Deadline: JulyJune
1, 2026
(+180150)
•
Avoidance Action trials begin: Week of August 17June
15, 2026
(+227164)

Mediation Provisions　•
Mediation immediately terminated as to all First Tranche
Defendants,
provided,
however,
that
First
Tranche
Defendants and Trustee may request mediation if jointly
requested and approved by Court.
•
Further Mediation Proceedings with Second Tranche
Defendantsmay
continue,
provided,
however,
such
proceedings
shall concludebe terminable by either party

or
by December 31, 2025.
•
On Jan. 6, 2026, Trustee shall filethe Mediator upon
written
notice asto the Mediator and parties
to
which
Second Tranche Defendants the Trustee has reached
settlement with (subject to Court approval) and which
claims remain in dispute.the specific
mediation.
Full and Partial Stay
Lifted as to All
Defendants　•
Full stay (3A) and partial stay (3B) are lifted as to all avoidance
action
defendants
(collectively
with
the
First
Tranche
Defendants and Second Tranche Defendants, "Defendants").
Written Discovery　•
Defendant Interrogatories / Requests for Admission
Entity:7
o
Joint by AllegedRelevant
Alter Ego
With
regard:
As
to issues related to disregarding the
corporate form of an alleged regarding
alter ego
entityentities involved in alleged
avoidable transfers,
all Defendants with transfers fromas to which
a
particular alleged alter ego entity
is relevant
shall
cooperate
to
issue
no
more
than

joint
interrogatories and 2515
joint requests for admission
per alleged alter ego entity.

4 The +[number] is the number of days from population of the Depository.

5 The date to commence production, which may be rolling based on a schedule agreed to by the Trustee and that particular Defendant.

6 Defendants would like to discuss with the Court a mechanism to potentially continue mediations with the agreement of the parties beyond December 31, 2025, if necessary.

7 This proposal is subject to the Trustee providing a schedule of all avoidance actions identifying the Defendant, the alleged alter ego transferor entities, and counsel of record (if any) to facilitate such joint efforts.

o
Unique by Defendant: Each Defendant may issue up to

interrogatories and 1510
requests for admission
related to all other issues in their particular avoidance
action.
o
Any Defendant may seek an increase in the number of
written discovery requests by agreement or order of the
Court.
•
Trustee's Interrogatories / Requests for Admission:
Maximum
of 25 interrogatories and 25 requests for admissions
for the
Trustee inas against
each pending avoidance action adversary
proceedingsDefendant,
subject
to
potential
increase
by
agreement or order of the Court.
•
To the extent the Defendants believe relevant documents and
information are not available or readily identifiable in the
Depository, they shall serve a draft request for production
identifying such documents and information ("Draft RFP"), and
promptly meet and confer with the Trustee to determine
whether such documents and information exist in the Trustee's
possession, custody, or control, or are identifiable in the
Depository.
If the parties cannot resolve this issue, such
Defendant(s) may seek relief from the Court to order production
of the documents and information identified in the Draft RFP
into the Depository.
•
Production of documents or information shall neither constitute
nor evidence waiver of attorney-client privilege or work
product doctrine (i.e., reciprocal non-waiver provision).

Trustee's Document
Depository and Privilege
Logs　•
Trustee intends to produce responsive documents through
Depository, organized into Data Rooms (further organized by
producing party), subject to Trustee's reservations that vast
majority of documents were produced to Trustee by third
parties,
Trustee
makes
no
representations
as
to
accuracy/authenticity of such documents, and inclusion of
documents does not constitute admission or basis to argue
documents are relevant/admissible or constitute admission of
any fact.
•
Access to depository shall be limited to counsel and defendants
that have signed operative Protective Order/Addendum and that
are engaged in discovery with Trustee under this Order.
Protective Order/Addendum shall otherwise apply in all
discovery proceedings under this Order.
•
Trustee will serve in the initial instance a categorical privilege
log identifying, for each category of withheld documents, (a)
general parties to such documents/ communications (e.g., the
Debtor and his bankruptcy counsel at a particular law firm), (b)
the general subject matter of the withheld documents (e.g., legal
advice related to bankruptcy filing), (c) the date range of the
documents in the category, and (d) the basis for the asserted
privilege (e.g., attorney-client privilege, work product, etc.).

The Trustee will meet and confer with defendants after
providing the categorical log if defendants believe further
information regarding privileges asserted by Trustee is required
as to any categories.

Deposition Discovery　•
Deposition discovery shall not commence prior to March
1816,

(+7573).
•
Trustee
and
Defendants
shall
cooperate
in
scheduling
depositions and ensuring
that Trustee and all
appearing
Defendants receive notice of any depositions.
•
Defendants shall share time and cooperate in posing questions
to witnesses and shall make their best efforts to not pose
duplicative questions.
•
Unless otherwise ordered by the Court, the parties shall depose
an individual or corporate representative one time, provided
that the time period specified in Rule 30(d)(1) may be enlarged
by agreement or order of the Court for good cause shown.
Expert Discovery　•
Any party that would like to disclose an expert under
Rule 26(a)(2)(A) shall provide such notice to the other
party by 60 days prior to the end of fact discovery. The
parties shall either stipulate to or seek an order of the
Court to set a schedule for the disclosures required under
Rule 26(a)(2)(B) and any expert-related discovery.
Trials / Intervention in
Omnibus Alter Ego
Actions　•
The Court shall hold a status conference approximately 21 days
prior to the close of fact discovery for the purpose of scheduling
any pre-trial and trial proceedings.
•
Defendants desiring to seek interventionThe Trustee will file a
motion requesting approval of similar procedures
in the
Omnibus Alter Ego Actions shall file a motion so that claims
may be litigated and tried under Rule 24 by December 31,
2025.42 to avoid duplication of efforts and redundant
proceedings.
•
Any trial proceedings
conducted by the Bankruptcy Court
shall
be sequenced and/or consolidated as appropriate, including
under Rule 42 (as made applicable by FRBP 7042), with
priority given to adjudicating first the issues in the Omnibus
Alter Ego Actionsclaims
involving postpetition transfers and
transfers involving entities already established as the Debtor's
alter egos by existing judgments.
Pre-Motion Requests
as
to Certain Motions　•
A pre-motion request (a "Pre-Motion Request") (of no more
than four pages) shall be filed prior to filing
or adjudication of
any motion under FRCP 12 or 56, which Pre-Motion Request

shall set forth the basis for the proposed motion, to which any
adverse party may file a written response (a "Pre-Motion
Response") (of no more than four pages) within fourteen (14)
days. For the avoidance of doubt, this
requirement shall apply
to any
Defendant subject to claims that had been fully stayed
under ¶¶
2(e)(i)
or 2(j)(iii)
of the May 2, 2024 Procedures Order
that filed a motion under FRCP 12 or 56 prior to or during such
stay.
•
After the filing of a Pre-Motion Request and any Pre-Motion
Response, the Court may rule on the papers as to whether the
requesting party may file the proposed motion or may schedule
a status conference to discuss the Pre-Motion Request.

Submission of Order and
Schedule　•
Trustee and Defendants shall submit a proposed order
incorporating these terms to the Court for each applicable
adversary proceeding.