--- type: court_doc id: "court_ctb_549_0" court: "CTB" case_no: "22-50073" doc_number: 549 doc_type: "MOTION" filed_date: "2022-07-12" lang: "en" machine_translated: false url: "https://mubeitech.com/en/court/court_ctb_549_0" json_url: "https://mubeitech.com/api/court/court_ctb_549_0" --- # Guo Wengui / Miles Guo — bankruptcy case · MOTION · ECF #549 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION x In re:　: :　Chapter 11 HO WAN KWOK,　: :　Case No. 22-50073 (JAM) Debtor.　: -----------------------------------------------------------　x **REPLY OF CHAPTER 11 TRUSTEE IN SUPPORT OF MOTION, PURSUANT TO BANKRUPTCY RULE 9006(c)(1), TO EXPEDITE HEARING ON APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PAUL HASTINGS LLP AS COUNSEL TO CHAPTER 11 TRUSTEE** Chapter 11 Trustee Luc A. Despins (the "Trustee"), by and through his undersigned proposed counsel, respectfully submits this reply (the "Reply") (i) in support of his *Motion, Pursuant to Bankruptcy Rule 9006(c)(1), to Expedite Hearing on Application of Chapter 11 Trustee for Entry of Order Authorizing and Approving Retention and Employment of Paul Hastings LLP as Counsel to the Chapter 11 Trustee*, dated July 12, 2022 (ECF No. 541, the "Motion to Expedite"); and (ii) in response to Pacific Alliance Asia Opportunity Fund L.P.'s ("PAX") Objection to the Motion to Expedite, dated July 13, 2022 (ECF No. 548).1 In support of this Reply, the Trustee respectfully states as follows: 1. For the reasons set forth in the Motion to Expedite, the Trustee continues to believe it is imperative for the Court to hear the Retention Application on an expedited basis to ensure that the Trustee has the assistance of legal counsel to help him address important, time-sensitive issues in this case. Nevertheless, after conferring with counsel to PAX, the Trustee would be amenable 1 Capitalized terms used but not defined herein have the meanings set forth in the Motion to Expedite. to having the Retention Application heard on July 25, 2022, or as soon thereafter that week as the Court is available. The Trustee understands that a July 25 hearing date is also acceptable to PAX. 2. To the extent it would be helpful to the Court, the Trustee is available next week for a status conference to provide the Court with an update as to the initial steps he has taken since his appointment and other developments in the case. Dated: July 13, 2022 LUC A. DESPINS, New Haven, Connecticut CHAPTER 11 TRUSTEE By: /s/ Patrick R. Linsey Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com and Nicholas A. Bassett (pro hac vice pending) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com and Avram E. Luft (pro hac vice pending) Douglass Barron (pro hac vice pending) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com Proposed counsel for the Chapter 11 Trustee UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION x In re:　: : Chapter 11 HO WAN KWOK,　: : Case No. 22-50073 (JAM) Debtor.　: -----------------------------------------------------------　x CERTIFICATE OF SERVICE The undersigned hereby certifies that on July 13, 2022, the foregoing Reply was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's system. Dated: July 13, 2022 New Haven, Connecticut > By: /s/ Patrick R. Linsey Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com > > and Nicholas A. Bassett (pro hac vice pending) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com and Avram E. Luft (pro hac vice pending) Douglass Barron (pro hac vice pending) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com Proposed counsel for the Chapter 11 Trustee