Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #950

## **IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

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HO WAN KWOK¹

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In re: : Chapter11

, : Case No. 22-50073 (JAM)

Debtor : October 12, 2022

## **REQUEST FOR PERMISSION ALLOWING ATTORNEY DANIELLE L. MEROLA, COUNSEL AT BAKERHOSTETLER, TO APPEAR REMOTELY FOR OCTOBER 13, 2022 HEARING**

Pursuant to section 105(a) of the Bankruptcy Code and Rule 1001 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), BakerHostetler ("Baker"), an interested party in the above-captioned case, respectfully moves the Court for permission for Attorney Danielle L. Merola to appear remotely at the hearing currently scheduled for Thursday, October 13, 2022 on the *Motion for Entry of Order Authorizing Compliance with Rule 2004 Subpoenas and Enforcing Consent Order Regarding Control of Attorney-Client Privilege and Work Product Protection Related to Rule 2004 Subpoenaed Documents and Information* (the "Compliance Motion", ECF No. 898). In support of the motion, BakerHostetler states as follows:

# **REQUESTED RELIEF**

1. On September 30, 2022, Chapter 11 Trustee Luc A. Despins (the "Trustee") filed a Motion to Expedite Hearing on *Motion of Chapter 11 Trustee For Entry of Order Authorizing Compliance with Rule 2004 Subpoenas and Enforcing Consent Order Regarding Control of Attorney-Client Privilege and Work Product Protection Related to Rule 2004 Subpoenaed*

¹ The Debtor is known by the following names: Guo Wengui; Miles Guo; Miles Kwok; and Ho Wan Kwok.

*Documents and Information* (ECF 900).

2. On October 5, 2022, the Court granted the Motion to Expedite Hearing re ECF No. 898 (ECF No. 917).

3. On October 12, 2022, Attorney Jeffrey M. Sklarz, on behalf of Baker, interested party, filed a Motion to admit Attorney Danielle L. Merola *pro hac Vice* on behalf of Baker to represent an interested party in the above-captioned case (ECF No. 947).

4. Attorney Danielle L. Merola works out of Florida. Given that the hearing was expedited and the time and expense needed to travel from Florida, Baker respectfully requests that Attorney Danielle L. Merola be permitted to participate in the Hearing via the Court's zoom platform.

### **CONCLUSION**

Baker therefore respectfully requests that Attorney Danielle L. Merola be permitted to appear remotely before this Court for the October 13, 2022 Hearing.

## BAKERHOSTETLER

By: /s/ Lawrence S. Grossman Lawrence S. Grossman (ct15790) Green & Sklarz LLC One Audubon Street, Third Floor New Haven, CT 06511 (203) 285-8545 Fax: (203) 823-4546 lgrossman@gs-lawfirm.com

#### **CERTIFICATE OF SERVICE**

I hereby certify that on the date set forth below a copy of the foregoing was served by CM/ECF and/or mail on anyone unable to accept electronic filing. Notice of this filing will be sent by email to all parties 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 CM/ECF System.

Date: October 12, 2022 /s/ Lawrence S. Grossman