Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #534

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

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In re: : CHAPTER 1 HON WO KWOK : Case No. 22-50073 (JAM) Debtor. :

#### **MOTION FOR ADMISSION** *PRO HAC VICE* **OF AVRAM EMMANUEL LUFT**

Pursuant to Local Rules of Civil Procedure 83.1 (c) and (d) of the United States District Court for the District of Connecticut, incorporated herein by Local Rules of Bankruptcy Procedure 1001-1 and 9083-3, Patrick R. Linsey, a member of the Bar of this Court and a member of the firm of Neubert, Pepe & Monteith, P.C. ("Neubert Pepe"), respectfully moves (the "Motion") this Court to enter an Order admitting Avram Emmanuel Luft ("Mr. Luft") *pro hac vice* on behalf of Chapter 11 Trustee Luc A. Despins (the "Trustee") in the above-captioned chapter 11 case (the "Case"). In support of this Motion, the undersigned represents the following:

1. The Trustee proposes to engage the law firm of Paul Hastings LLP ("Paul Hastings"), 200 Park Avenue, New York, NY 10166, to serve as his counsel and to engage the law firm of Neubert Pepe to serve as his local counsel in this Case. It is anticipated that applications to approve the foregoing will be filed this week.

2. Mr. Luft is of counsel to Paul Hastings. He is a member in good standing of the bar of the State of New York (Registration No. 3058047) and of the United States District Courts for the Southern District of New York, the Eastern District of New York, and the Eastern District of Michigan, and of the United States Courts of Appeals for the Second Circuit and the Ninth Circuit. Mr. Luft has not been denied admission or disciplined by any Court.

3. Mr. Luft has executed an affidavit in connection with this Motion which has been attached hereto as Exhibit A.

4. The undersigned counsel is a member in good standing of the bar of the State of Connecticut. The undersigned is also admitted to practice before the United States District Court for the District of Connecticut and the Southern and Eastern Districts of New York.

5. The undersigned respectfully requests that, pursuant to D. Conn. L. Civ. R. 83.1(d), in the event that this motion is granted, he be excused from attendance at proceedings. In accordance with D. Conn. L. Civ. R. 83.1(c), the undersigned agrees to accept service on behalf of Mr. Luft.

WHEREFORE, Patrick R. Linsey respectfully requests that this Court enter an Order granting Avram Emmanuel Luft admission *pro hac vice*.

New Haven, Connecticut

Dated: July 11, 2022 RESPECTFULLY SUBMITTED

*/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

# EXHIBIT A

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

X . .

:

In re:

CHAPTER 1

HON WO KWOK

Debtor.

)

Case No. 22-50073 (JAM)

### AFFIDAVIT IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE OF AVRAM EMMANUEL LUFT

STATE OF NEW YORK COUNTY OF NEW YORK )

) ss: New York

Avram Emmanuel Luft, of full age, deposes and states the following:

1. I am an attorney and of counsel to the firm of Paul Hastings LLP ("Paul Hastings"), with an office address of 200 Park Avenue, New York, NY 10166. The firm's telephone number is (212) 318-6079, the facsimile number is (212) 303-7079, and my email address is aviluft@paulhastings.com.

2. Paul Hastings is proposed counsel for Chapter 11 Trustee Luc A. Despins (the "Trustee") in the above-captioned chapter 11 case (the "Case") to provide legal representation in connection with this Case. It is anticipated that the Trustee will file an application to employ Paul Hastings in this Case this week.

3. Pursuant to D. Conn. L. Civ. R. 83.1(c), Patrick R. Linsey of the law firm of Neubert, Pepe & Monteith, P.C., will serve as my local bankruptcy counsel. Neubert, Pepe & Monteith, P.C.'s address is 195 Church Street, 13th Floor, New Haven, Connecticut, 06510.

4. Pursuant to D. Conn. L. Civ. R. 83.1(d), I designate the District of Connecticut as

the forum for any resolution of any dispute arising out of my admission.

5. I am a member in good standing of the bar of the State of New York (Registration No. 3058047) and of the United States District Courts for the Southern and Eastern Districts of New York and the Eastern District of Michigan, and of the United States Courts of Appeals for the Second Circuit and the Ninth Circuit. I have no pending disciplinary complaints as to which a finding has been made that such complaint should proceed to a hearing. Further, I have not been denied admission to, been disciplined by, resigned from, surrendered my license to practice before, or withdrawn an application for admission to practice before this Court or any other court, while facing a disciplinary complaint.

6. I have read and am familiar with the Federal Rules of Civil and Criminal Procedure, the Local Rules of the United States District Court for the District of Connecticut, the Local Rules of the Bankruptcy Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct, and will abide by and comply with the substantive and procedural requirements of the local rules and the administrative orders of this Court.

Avram Emmanuel Laft

Sworn and subscribed to before me this 11th day of July, 2022.

Notary Public My Commission Expires: do to Do. 205

ALEJANDRO ROJAS NOTARY PUBLIC, STATE OF NEW YORK NO.01RO6360799 QUALIFIED IN SUFFOLK COUNTY MY COMMISSION EXPIRES JUNE 26,2025

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

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Debtor. :

In re: : CHAPTER 1

HON WO KWOK : Case No. 22-50073 (JAM)

### **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on July 11, 2022, the foregoing Motion was electronically filed. Notice of this filing will be sent by e-mail to all parties by operation of the Court's case management/electronic filing (CM/ECF) system or by mail to anyone unable to accept electronic filing pursuant to the Notice of Electronic Filing. Parties may access this filing through the Court's system.

Dated: July 11, 2022 New Haven, Connecticut

> */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