Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #716

| From: | Bongartz, Alex <alexbongartz@paulhastings.com></alexbongartz@paulhastings.com> | |--------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Sent: | Friday, August 5, 2022 2:33 PM | | TO: | CTBdb_CourtroomDeputy_Bridgeport | | CC: | Holley.L.Claiborn@usdoj.gov; igoldman@pullcom.com; pfriedman@omm.com; | | | laronsson@omm.com; ssarnoff@omm.com; ehenzy@zeislaw.com; | | | SKindseth@zeislaw.com; ccallari@callaripartners.com; Despins, Luc A .; Barron, Douglass | | | E .; plinsey@npmlaw.com; Doug Skalka | | Subject: | In re Kwok / Case No. 22-50073 (JAM) - Further Revised Proposed Corporate | | | Governance Order | | Attachments: | In re Kwok -- Further Revised Proposed Corporate Governance Order ( blackline),pdf; In<br>re Kwok -- Further Revised Proposed Corporate Governance Order (clean).pdf |

## CAUTION - EXTERNAL:

To the Chambers of the Honorable Julie A. Manning:

Further to yesterday's hearing on the chapter 11 trustee's corporate governance motion [ECF No. 598] and the related revised proposed orders [ECF Nos. 645, 671, and 681], please see attached:

- (1) A clean version of the further revised proposed order, reflecting the changes directed by the Court at yesterday's hearing as well as two additional, minor changes (as further detailed below); and - (2) A blackline version of the further revised proposed order, marked to show changes against the version filed with the Court on August 4, 2022 [ECF No. 681]. (The attached blackline does not include Exhibit A to the order, because no further changes have been made to Exhibit A.)

The attached further revised proposed order reflects two additional, minor changes.

First, earlier today, the chapter 11 trustee received a few final comments from UK counsel (Harcus Parker Limited) on the form of letter to UK counsel, which are reflected in the final form of letter in Exhibit B to the further revised proposed order attached to this email. (A copy of the final form of letter was also provided to the debtor prior to sending this email to Chambers.) Accordingly, there is no need to include an interim deadline for the chapter 11 trustee to provide a final form of the lebtor, and the five business days period for the debtor to sign and deliver the letter to UK counsel can commence upon entry of the order.

Second, after further conferring with BVI counsel, the chapter 11 trustee has determined that it is not necessary for Mr. Kwok to sign the transfer-in pack to the new BVI agent for Genever Holdings Corporation, but that the chapter 11 trustee can submit the form himself, subject to the debtor providing certain missing information to the chapter 11 trustee. (The chapter 11 trustee has already emailed counsel to the list of questions to allow the chapter 11 trustee to complete the form.) Paragraph 3(a) to the attached revised proposed order reflects this (minor) modification. Prior to submitting the attached revised proposed order, the chapter 11 trustee also shared a draft of the revisions to paragraph 3(a) with counsel to the debtor. As of the time of this email, counsel to the debtor has not raised any objections to this language.

Respectfully submitted,

Alex Bongartz

G. Alexander Bongartz | Of Counsel | Financial Restructuring Group PAUL Paul Hastings LLP | 200 Park Avenue, New York, NY 10166 | Direct: +1.212.318.647. H A S T I N G S Mobile: +1.617.838.5117 | Main: +1.212.318.6000 | Fax: +1.222.31. H A S T I N G S Mobile: +1.617.838.5117 | Main: +1.212.318.6000 | Fax: +1.212.30.7072 | Fran alexbongartz@paulhastings.com | www.paulhastings.com

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