Guo Wengui / Miles Guo — criminal case · EXHIBIT · ECF #198-10

HO WAN KWOK and GENEVER * Bridgeport, Connecticut

\* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \*

#1831 INTERIM APPLICATION FOR COMPENSATION FOR PAUL HASTINGS LLP, TRUSTEE'S ATTORNEY FE>EXPENSES \$348,813.54

#1851 INTERIM APPLICATION FOR COMPENSATION FOR NEUBERT, PEPE & MONTEITH, P.C., TRUSTEE'S ATTORNEY FEE:

#1870 APPLICATION PURSUANT TO BANKRUPTCY CODE SECTIONS 327(e), 328(a) and 3,(a), BANKRUPTCY RULES 2014 and 2016 and LOCAL BANKRUPTCY RULES 2014-1 and 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF SAXE DOERNBERGER & VITA, P.C. AS

Proceedings recorded by electronic sound recording, transcript produced by transcription service.

Fiore Reporting and Transcription Service, Inc.

APPEARANCES:

Chapter 11 Trustee: LUC A. DESPINS, ESQ.

200 Park Avenue New York, NY 10166 For the Chapter 11 Trustee: G. ALEXANDER BONGARTZ, ESQ. Paul Hastings LLP 200 Park Avenue New York, NY 10166

PATRICK R. LINSEY, ESQ. Neubert Pepe & Monteith, PC 195 Church Street New Haven, CT 06510

For the U.S. Trustee: HOLLEY L. CLAIBORN, ESQ.

Office of the U.S. Trustee 150 Court Street New Haven, CT 06510

For the Creditors Committee: IRVE J. GOLDMAN, ESQ. Pullman & Comley 850 Main Street Bridgeport, CT 06601

Ho Wan Kwok - June 29, 2023 3 1 (Proceedings commenced at 10:05 a.m.) 2 THE COURTROOM DEPUTY: Case No. 22-50073, Ho Wan 3 Kwok and Genever Holdings, LLC. 4 THE COURT: Good morning. If we could have 5 appearance for the record starting with the Chapter 11 6 Trustee please. 7 MR. DESPINS: Good morning, Your Honor. Luc 8 Despins, Chapter 11 Trustee. 9 THE COURT: Good morning. 10 MR. BONGARTZ: Good morning, Your Honor. Alex 11 Bongartz, of Paul Hastings, for the Chapter 11 Trustee. 12 THE COURT: Good morning. 13 MR. LINSEY: Good morning, Your Honor. Patrick 14 Linsey of Neubert Pepe & Monteith, Connecticut counsel for 15 the Trustee. 16 THE COURT: Good morning. 17 MS. CLAIBORN: Good morning. Holley Claiborn for 18 the U.S. Trustee. 19 THE COURT: Good morning. 20 MR. GOLDMAN: Good morning, Your Honor. Irve 21 Goldman, Pullman & Comley, for the Creditors Committee. 22 THE COURT: Good morning. 23 All right. So there are three matters on the 24 calendar this morning, two are fee applications and one is 25 an application to employ counsel.

Ho Wan Kwok - June 29, 2023 4 1 How would you like to proceed, Trustee Despins? 2 MR. DESPINS: I can start with the application to 3 retain the counsel, if that's okay. 4 THE COURT: Go right ahead. Yes. Thank you. 5 MR. DESPINS: Thank you, Your Honor. And good 6 morning again. Luc Despins, Chapter 11 Trustee. 7 And this is the application to retain the firm of 8 Saxe Doernberger & Vita. They're based in Connecticut. And 9 the fee application is at docket 1870. 10 And they are -- they were retained to handle 11 insurance coverage disputes relating to AIG, as Your Honor 12 is familiar because you've interacted with them already. 13 And we filed the application. And we received no 14 objections. And, therefore, subject to any changes you may 15 have to the order we would ask the Court to enter the order. 16 THE COURT: The only question I have with regard 17 to the engagement of this counsel is, and I apologize, I 18 don't have it in front of me so I don't recall, is are they 19 being paid on an hourly basis? 20 MR. DESPINS: Yes. 21 THE COURT: Okay. 22 MR. DESPINS: Yes, they are, Your Honor. 23 THE COURT: All right. And they're -- and they'll 24 be submitting fee applications? 25 MR. DESPINS: Correct, Your Honor.

Ho Wan Kwok - June 29, 2023 5 1 THE COURT: Okay. The only reason I asked is 2 sometimes I miss if there's some other form of compensation 3 requested under 328 at the beginning -- 4 MR. DESPINS: Yeah. 5 THE COURT: -- of a -- of a retention of 6 professional, but I didn't think that was true in this case. 7 But I didn't recall. 8 MR. DESPINS: It's hourly rates, Your Honor. 9 THE COURT: Okay. Thank you. 10 I don't -- I do not have any questions. 11 I understand why you would like to retain special 12 counsel and the documents that I've seen certainly support 13 the application. 14 I'm looking at the proposed order. And the only 15 reason I asked the question was because of the reference to 16 328. But it's 328(a) which is the Trustee's ability to 17 retain counsel. So I don't have a problem with it. 18 But does anyone else wish to be heard on the 19 application to employ special insurance counsel? 20 MS. CLAIBORN: Just briefly, Your Honor. 21 The U.S. Trustee filed a statement of no objection 22 to the application. That's at ECF 1941. 23 THE COURT: Okay. Thank you. 24 MS. CLAIBORN: And just to be clear the reference 25 to 328 in the application in no way interferes with the

Ho Wan Kwok - June 29, 2023 6 1 ability of the Court or the U.S. Trustee or creditors to 2 opine on the reasonableness of the fees when they're sought. 3 THE COURT: Yeah. Often, and I saw that when I 4 looked back at the retention of Paul Hastings and Neubert 5 and Pepe as well, often 328 isn't mentioned. It's just 327. 6 So I just -- I like to make sure when 328 is 7 mentioned that no one is, and no one is in this case, but 8 insisting that there's some kind of compensation that's set 9 from the beginning. 10 Because as you all know there's a lot of case law 11 that says, you know, you can't touch that once that's done 12 or it's very limited ability. So that's fine. 13 The only thing that I don't see, and maybe I 14 missed it, so let's just -- let me -- oh, it is there -- 15 it's there, I just -- effective May 11. That's what I'm 16 asking. What was the date that they retained as of and it's 17 May 11th. I see it now in paragraph 2 of the ordered 18 paragraphs. 19 So does anyone else wish to be heard? 20 MR. GOLDMAN: Just the committee has no objection, 21 Your Honor. 22 THE COURT: Okay. Thank you. 23 As I stated already, I've reviewed the 24 application. I understand why the Trustee is seeking to 25 retain special counsel. Certainly understand under the

Ho Wan Kwok - June 29, 2023 7 1 specific facts and circumstances of the cases in the 2 adversary proceeding involving the insurance the need for 3 special counsel to deal with or help the Trustee deal with 4 the insurance issues. 5 No one has filed any written objection to the 6 application to employ. There is no one participating in 7 this hearing today that is objecting to the application to 8 employ. The United States Trustee's Office has filed a 9 statement of no objection with regard to the application to 10 employ, which is ECF No. 1941. 11 For all those reasons the application is granted 12 and the proposed that was submitted with the application can 13 enter. 14 MR. DESPINS: Thank you, Your Honor. 15 I would just point out that they are not only 16 insurance coverage counsel, but also local Connecticut 17 counsel -- 18 THE COURT: Sure. 19 MR. DESPINS: -- because Mr. Linsey's firm -- 20 actually, we can say that it's Mr. Linsey's firm because 21 he's now a partner at his firm -- that has a conflict and 22 that was my way of mentioning that he made partner. 23 THE COURT: That he did or did not? 24 MR. DESPINS: He did. He did. Just did. 25 THE COURT: Oh, well, congratulations, Mr. Linsey.

Ho Wan Kwok - June 29, 2023 8 1 MR. LINSEY: Thank you, Your Honor. 2 MR. DESPINS: So they're also local counsel so 3 that, you know, that covers that. 4 Thank you, Your Honor. 5 THE COURT: Okay. Thank you. 6 MR. DESPINS: So the next matter I would move on 7 to would be the interim application for -- to retain -- to 8 pay Paul Hastings. 9 And, Your Honor, so that I'm not going to take a 10 lot of time on this, but I would -- there are two aspects I 11 want to cover. 12 One is I want to describe and reflect the 13 settlements that were agreed to with the U.S. Trustee and 14 the committee. 15 And then I'll have very short, very short 16 editorially comments about some aspects of the fees here. 17 But first, on the settlements, as you can imagine, 18 in the background there are a lot of discussions that were 19 taking place with both the U.S. Trustee and the committee. 20 One of the issues that was being discussed was the issue of 21 holdbacks. 22 And our initial position was that there should be 23 no holdbacks during the case because there's a contingent 24 fee deal and we haven't gotten paid. And on top of that 25 there was a built-in holdback because this application only

Ho Wan Kwok - June 29, 2023 9 1 covers through February. So there's March, April, May, 2 June, plenty of money to cover a holdback. 3 But the counter from their point was, which was a 4 good one, which is, well, what stops you from filing an 5 application on Friday that brings all that up and there will 6 be no holdbacks at all? 7 And so we agreed as part of this back and forth 8 that any future application would be subject to a 20 percent 9 holdback provided that we -- that we're getting paid -- and 10 this applies to all professionals in the case -- on a more 11 regular basis which we defined at no more than 60 days. 12 So, for example, we're not going to file an 13 application tomorrow, but if we did, and it is heard and 14 paid, subject to Your Honor's decision to allow or not 15 allow, within 60 days, then there would be 20 percent held 16 back for the rest of the case for that application. 17 And the concept there is if now we're getting -- 18 we have money, we're getting into a more regular mode where 19 -- where fee applications can be heard and can be dealt 20 with. 21 And so that was the agreement that was reached, 22 which is that there will be a 20 percent holdback going 23 forward for all future fee applications provided that we are 24 operating in this normal mode which is defined as, you know, 25 no more than 60 days or so.

Ho Wan Kwok - June 29, 2023 10 1 So that's -- so that's the first part on 2 holdbacks. I wanted to mention that discussion with the 3 U.S. Trustee and with the committee on that. 4 The second part is the U.S. Trustee raised a 5 number of issues with some of the time entries. And to give 6 you some examples, too many lawyers at a hearing or vague 7 entries. 8 And so to be candid with you counsel for the U.S. 9 Trustee was correct on some of the issues regarding too many 10 lawyers at a hearing, although frankly sometimes I was alone 11 at a hearing, but I guess that doesn't -- that doesn't 12 counter that argument, but she was right on that issue. 13 And on a vague entry we -- it's all subject to 14 disagreement. 15 We didn't agree with the bulk of her comments, but 16 at the end of the day we agreed to a \$550,000 reduction, 17 Your Honor, which we think is substantial to address all 18 these issues. 19 And we've -- I would say we took on some comments 20 that the U.S. Trustee had in terms of making it easier for 21 the U.S. Trustee and for parties in interest and for the 22 Court to ascertain the value provided with respect to 23 adversary proceedings. 24 So from no on the next applications that are filed 25 will have every adversary proceeding billed separately so

Ho Wan Kwok - June 29, 2023 11 1 that we can look at the adversary proceeding and say, wow, 2 you know, it cost us more than we recovered, which would not 3 be good, or hopefully it will be, no, we recovered more than 4 we spent. But I think that it was a very good suggestion.

5 We're going to implement that going forward so all 6 future fee applications will have separate categories for 7 each adversary proceeding so that the Court can see that.

8 I would say on the reduction I don't think -- I 9 don't want this to be precedent setting in a sense that we 10 now know what issues were raised, we're not going to 11 hopefully repeat these issues, so that -- so that we won't 12 be in the same position, but clearly in order to get this 13 resolved with the U.S. Trustee we agreed to the \$550,000 14 reduction. And as I said we think it's a material 15 reduction.

16 So before I move on to what I call my short 17 editorial comments, maybe the committee or the U.S. Trustee 18 wants to address this aspect of -- or later -- it's up --

19 MR. GOLDMAN: Well, I did want to mention it 20 wasn't my understanding that the future 20 percent holdbacks 21 would be subject to any shortening of the time for filing 22 fee applications under Section 331.

23 We have no objection to the Court doing that 60 24 days or even a shorter period, but it wasn't my 25 understanding that this agreement with the committee was

Ho Wan Kwok - June 29, 2023 12 1 conditioned on the Court doing that. 2 THE COURT: You can have a conversation. Go 3 ahead. 4 (Pause) 5 MR. DESPINS: We want the Court to reduce the time 6 to hear and decide fee applications to a 30-60 day period. 7 But counsel is right that I'm taking the risk that 8 the Court would refuse to do that and would only hear fee 9 applications on a four-month interval which is in the 10 statute. I'm sorry. He's correct. 11 THE COURT: Okay. 12 MR. DESPINS: And there's no relief pending before 13 the Court on that. 14 THE COURT: Right. 15 MR. DESPINS: We hope that Your Honor will do 16 that, but I'm taking a risk that the Court will refuse to do 17 that. So that covers the committee. 18 MR. GOLDMAN: Yes. 19 MS. CLAIBORN: Your Honor, with respect to the 20 U.S. Trustee's points on the reductions requested, we did 21 reach a consensual number which is memorialized in the 22 statement that I filed on the docket at ECF 1949. 23 If the Court has any questions about that, I'm 24 happy to answer them. 25 THE COURT: I'm not sure I have questions per se.

Ho Wan Kwok - June 29, 2023 13 1 I think that I can understand the discussions that 2 have -- were had and Trustee Despins said about certain 3 entries being vague or having many -- too many lawyers at a 4 hearing or things like that. 5 I will say that I agree with Trustee Despins that 6 this is not some kind of precedent set in this case if and 7 when further fee applications are filed. I think every fee 8 application has to be reviewed separately from any fee 9 application that's been filed previously. 10 I think that in connection with this case and what 11 I have observed in this case that the -- there has been -- 12 this has been a heavily litigated case to put it mildly. 13 And I think that the Trustee has attempted to keep 14 costs and fees in a range that is reasonable under the very 15 specific and detailed circumstances of this -- these cases 16 and the numerous adversary proceedings. 17 And so I completely understand the discussions. I 18 think the discussions are healthy. I think they should 19 happen. I've no issue with that. But I don't think it 20 should be something that everyone expects on a going-forward 21 basis. 22 The Court, as you know, has an independent 23 obligation to review the fees as well. Otherwise why am I 24 here, right? I mean, there's really no point. 25 So there are -- I mean, I think anyone could go

Ho Wan Kwok - June 29, 2023 14 1 through any fee application of any magnitude, whether it's a 2 thousand dollars or \$12 million, and make a determination or 3 suggestion that time should be reduced. 4 But I don't -- I want to be clear that I don't -- 5 I will not -- someone will not be successful in arguing 6 before me, well, that was done last time so you should do it 7 again. That will not be a successful argument. 8 This is a very -- I mean, I don't have to tell 9 anybody in this room this is a very unusual case that has 10 been heavily, heavily litigated at every step. I can't 11 think of -- I guess today maybe is the only day we haven't 12 had an objection which is fascinating in and of itself. 13 But, you know, every single time something has 14 been filed there's an objection, there's the discovery 15 disputes, often for whatever reason we all come ready to 16 think that there's going to be a controversy and then 17 there's some resolution, but the Trustee had to prepare for 18 that and be ready for that. 19 And so all I want to say is, again, of course you 20 should have these conversations. They're very -- they can 21 be very productive and they should happen. 22 But I just want to be very clear that that does 23 not mean that I expect that every fee application that's 24 filed should have a voluntary reduction, number one. 25 Number two, even if it doesn't have a voluntary

Ho Wan Kwok - June 29, 2023 15 1 reduction, the Court may reduce it. The Court may look at 2 something and say, you know, I don't think that is 3 reasonable under the circumstances of the case. 4 I do think the suggestion of billing separately or 5 accounting separately for the time in the adversary 6 proceedings at this point is a good suggestion given where 7 things stand now and how they've developed. But as we all 8 know things change in this case every day. One minute we're 9 going down one road and the next minute we're going down 10 another. 11 And this is not a case that fits in my opinion 12 into the mold of where you could draft a litigation plan of 13 how you're going to handle this case. 14 And so for those reasons I just wanted to be clear 15 that this does not set any precedent in this case with 16 regard to an expectation that any professional must reduce 17 their fees, with the comment that doesn't mean they won't be 18 reduced. Okay? 19 But there's no -- I'm not -- this case is -- you 20 know -- as you know, I've looked by the way at the fee 21 applications and the time entries that are, you know, what, 22 four or five inches thick and the work appears very 23 reasonable to me under the circumstances of this case. 24 Now, someone could say that's a lot of money, and 25 that's true, but the Trustee did -- from my perspective with

Ho Wan Kwok - June 29, 2023 16 1 regard to this fee application and the time frame that is 2 covered by this fee application, the Trustee and Connecticut 3 counsel for the Trustee have not -- I see no evidence in the 4 fee application entries which I looked at -- 5 Now, did I study every single entry, of course 6 not, I can't. 7 But I looked at the time entries. I looked at 8 them. I looked at the categories. I looked at the 9 breakdown of the amounts by category. 10 But I don't -- I did not see an entry that 11 concerned me, that made me think why did they do that? Or 12 that seems unnecessary. Or I didn't see an entry that, you 13 know, which happens some times, where it was mistakenly put 14 in from another case. I mean, that's happened before. You 15 know, somebody makes a mistake. You know, that happens. 16 It's not a -- nobody did it on purpose. 17 I didn't see anything that raised any concern from 18 the Court's perspective. And I think that this is a case 19 that required the staffing that occurred up to this point. 20 Up to the point, you know. 21 What's going to happen from this point forward, 22 who knows, right? Things we don't know. That's the -- 23 that's what happens in this case. We don't know from day to 24 day how it's going to be. So I just -- I just want to be 25 clear about that. I think I have been. I've probably said

Ho Wan Kwok - June 29, 2023 17 1 it three times now. 2 But I just think that the dollar amount, while 3 high, appears to me to be reasonable under the very specific 4 circumstances of this case. 5 And the expenses as well. I mean, you know, we 6 all know what it costs to do these things especially if 7 you're met every step of the way with opposition. 8 And I have no idea, but I would -- if the Court -- 9 if it was known what was spent by counsel opposing all these 10 things, I think we'd find that would be a high number as 11 well. 12 So I have no problem with the agreement that 13 you've reached. And I think I need a new order though, 14 don't I? 15 MS. CLAIBORN: You do. 16 MR. DESPINS: Yes. And I believe Mr. Bongartz 17 sent a draft to the courtroom deputy this morning. 18 THE COURT: Okay. I haven't seen it yet. But 19 that's not your -- I mean, you know, we've been working so 20 we probably just didn't know that it was there yet. 21 But I would assume that when I look at the 22 original proposed order the differences would say that 23 you've agreed to a reduction. 24 MR. DESPINS: Yes. 25 THE COURT: That is has the dollar amounts in it.

Ho Wan Kwok - June 29, 2023 18 1 That you say that there was a hearing held today that -- I 2 don't know if you said it in the -- if you need to have said 3 it, but we can put in today's date. If that's all we need 4 to put in, we can put it in. 5 MR. DESPINS: But there were other changes, Your 6 Honor, I should point out to Your Honor. 7 They're not material but Mr. Kindseth asked that 8 we incorporate by reference the DIP order. Remember about 9 disgorgement and all that? And we've agreed to do that. 10 That's in the revised order that you have. 11 THE COURT: I was going to say not the DIP order. 12 MR. DESPINS: No, the sale. 13 THE COURT: There is no DIP. That was withdrawn. 14 MS. CLAIBORN: The sale. 15 MR. DESPINS: Okay. 16 THE COURT: Yeah. 17 MR. DESPINS: I'm talking about another case now. 18 THE COURT: That's okay. That's okay. 19 MR. DESPINS: Yeah. The sale order. 20 THE COURT: So what's the reference that he wants 21 in there? 22 MR. DESPINS: Remember that there was a -- the 23 provision that you correctly pointed out that Ms. Guo should 24 not be a party to -- it's that provision that says that if 25 they win in the Supreme Court that they own it --

Ho Wan Kwok - June 29, 2023 19 1 THE COURT: Oh, that the monies, they could get 2 monies back from the estate? 3 MR. DESPINS: From the estate. And if there's no 4 money in the estate, from the professionals that got the 5 money. So that's us. 6 THE COURT: Okay. Okay. I understand. 7 MR. DESPINS: So we've added that. 8 We also added other requests of counsel for the 9 U.S. Trustee, some language that -- because Your Honor 10 ordered a number of parties to pay 78 or \$73,000 in fees. 11 We haven't collected on that yet so there's a provision -- 12 THE COURT: In connection with the sanctions 13 orders? 14 MR. DESPINS: Exactly. 15 THE COURT: Yes. 16 MR. DESPINS: That if we ever collect that we need 17 to give a credit in the next fee app, so we added that 18 language. 19 THE COURT: Okay. 20 MR. DESPINS: And I believe that's all that was 21 added. 22 THE COURT: Okay. That's fine. That's fine. 23 And I'm looking at what was the original proposed 24 order and -- 25 MR. DESPINS: And we had put the local rule --

Ho Wan Kwok - June 29, 2023 20 1 THE COURT: Right. 2 MR. DESPINS: -- provision -- 3 THE COURT: Right. 4 MR. DESPINS: -- regarding disgorgement. 5 THE COURT: Yeah. And it does say -- and no 6 objection to the application having been filed, and that is 7 accurate. 8 You know what? I might change -- it says and no 9 objection to the application having been filed by the Office 10 of the United States Trustee. And in the absence of any 11 other objection to the application. Well, that's right. So 12 that's fine. 13 I just want to make it clear that no one's filed 14 an objection, which I think it is. Okay. 15 So I -- you know, for the reasons that I've just 16 stated, and for what the Court's obligations are with regard 17 to a fee application, with regard Paul Hastings and the fees 18 and expenses incurred from the period of July 8th, 2022 19 through February 28th, 2023, I find that the fees and 20 expenses sought are reasonable and that they were necessary 21 under the circumstances of the case. 22 Now, we could argue that it's -- they were 23 unfortunately necessary, but they were necessary. And it 24 wasn't through -- there's been no demonstration in the fee 25 application that I've seen that there were any tasks or time

Ho Wan Kwok - June 29, 2023 21 1 incurred that were inappropriate under the -- under what was 2 the charge given to the Trustee to investigate the affairs 3 of the debtor in connection with the appointment of the 4 Chapter 11 Trustee. 5 And I appreciate the conversations between the 6 U.S. Trustee and the Trustee. 7 And I appreciate the statement filed by the 8 Trustee, United States Trustee, regarding that they had no 9 objection to the fee application in connection with an 10 agreement to reduce the fees and no one else having filed 11 any objection to the fees. 12 Does anybody else wish to be heard before I rule? 13 MR. GOLDMAN: Your Honor, just briefly. 14 I didn't want the Court to think the committee was 15 just rolling over on this. We did scrutinize the 16 application, came to pretty much the same conclusion Your 17 Honor came to after getting over the initial sticker shock 18 of the number. 19 But I think from our perspective on calmer 20 reflection it was more of a function of the hourly rates, 21 which were disclosed at the outset, so we really couldn't 22 take issue with that. 23 And recognizing as Your Honor has said the 24 difficult issues that were confronted in this case, the 25 progress that's been achieved thus far, which the committee

1 of you, I can look, it won't take me long, but aren't they 2 jointly and severally liable on those? 3 MR. DESPINS: They are. 4 MR. GOLDMAN: Yes. 5 MR. BONGARTZ: They are. 6 THE COURT: Okay. I don't know that it says that. 7 I wouldn't mind if it did.

8 say -- no, we can do it -- I mean, it can say are jointly 9 and severally obligated to pay. 10 MR. DESPINS: Okay. 11 MS. CLAIBORN: That's fine. 12 MR. DESPINS: Your Honor, we'll do that change. 13 THE COURT: Yeah. We'll do that change. 14 I'd like -- you know, who knows if this is going 15 to be appealed, right? 16 So I'd like the district court to understand as 17 clearly as possible what's happened so that they don't have 18 to do the work if there's an appeal. Okay? 19 So I'm looking -- I'm turning to the courtroom 20 deputy, do you see where I am in paragraph 4? 21 THE COURTROOM DEPUTY: Yes.

22 of HK? 23 THE COURT: Right.

24 severally obligated. Okay?

25 whatever, you know, after, but I think that's -- I know the

1 order says that, but I'd like it to say -- I would like that 2 same language to be in this order. 3 MR. DESPINS: I would just say, Your Honor, you 4 mentioned the district court, there's a lot of activity in 5 the district court at this point, meaning appeals, state -- 6 THE COURT: I've heard. 7 MR. DESPINS: You know, that was part of my 8 speech, so I'm not going to go through that, but over 36-37 9 years I thought I'd seen it all, but I've never seen a 10 double stay pending appeal. What I mean is that both courts 11 being asked to stay at the same time. Never seen that. 12 Never seen a mandamus which they filed. 13 I mean, I was telling Ms. Claiborn that I've often 14 dreamt about filing a mandamus before a judge that ruled 15 against me, but I've never seen, ever seen that. 16 So there's a lot of activity in the district court 17 at this point. 18 THE COURT: I understand both of those things that 19 you just said and I guess we'll see what happens. 20 I mean, it's in the district court's hands 21 obviously. Whatever the district court's going to do, the 22 district court is going to do. 23 I do know -- I did appreciate knowing that Judge 24 Dooley did deny the motion for stay pending appeal because 25 then I don't have to rule on that. That helps.

Ho Wan Kwok - June 29, 2023 25 1 And I know I understand that there's a writ of 2 mandamus out there in which the docket indicates that I'm a 3 defendant. Although I think that's not accurate. I think 4 that's just the way the clerk's office has to -- I don't 5 know that though -- but I think it's the way the clerk's 6 office to note it. 7 And then I think it's completely up to the 8 district court to determine what if anything will happen 9 with that writ of mandamus, including whether or not the 10 district court may ask some party in this case to file 11 pleadings. So I have no idea. 12 No, I hadn't seen one of those either actually. 13 MR. DESPINS: As I said, I've dreamt a lot about 14 that in other cases, but I've never actually seen it. 15 THE COURT: Well, I've seen it in a context of a 16 motion where there was other relief sought before the other 17 court, but not in the commencement of an action. I hadn't 18 seen that. 19 But, you know, we should all go back and read 20 Marbury vs. Madison so maybe we'll -- 21 MR. DESPINS: Exactly. 22 THE COURT: -- understand what that -- once we 23 read that again. But that wasn't involving a judge, so 24 we'll see. 25 In any event, I'm looking at the proposed order

Ho Wan Kwok - June 29, 2023 26 1 that was submitted this morning. And with the changes that 2 I noted on the record and that are agreeable to the parties 3 that are here today, the application for compensation of 4 Paul Hastings, LLP for the period of July 8th, 2022 through 5 February 28th, 2023 is granted and the proposed order with 6 the minor changes noted on the record will enter. 7 MR. DESPINS: Thank you, Your Honor. 8 THE COURT: Thank you. 9 MR. LINSEY: Good morning, Your Honor. 10 THE COURT: Good morning. 11 MR. LINSEY: Patrick Linsey, Connecticut counsel 12 for the Trustee and conflicts counsel here for my firm 13 Neubert, Pepe & Monteith. I won't take up a lot of time. 14 I was involved on behalf of my firm in the 15 conversations that the Trustee discussed with the U.S. 16 Trustee and with the committee regarding holdbacks and fee 17 applications going forward and I understand the parameters 18 that we're operating under. 19 I could -- I could talk about what led to the 20 filing of this fee application, but I feel like everyone on 21 this courtroom has pretty much lived it together at this 22 point. 23 There is one thing that I'll briefly touch on, 24 which is I think not always the shiniest and most exciting 25 part of the case, it's sort of the ducks' feet under the

Ho Wan Kwok - June 29, 2023 27 1 water if you will, but it's also sort of an apt analogy 2 because it's in some ways what powers the case, which is the 3 investigation that's been going on while we've been doing 4 all this litigation. 5 I think there have been five omnibus 2004 motions 6 that have been granted, that's on top of three initial 2004 7 motions that have been granted, all of which refer -- all of 8 which dealt with numerous examinees, dozens and dozens, into 9 the hundreds I believe at this point, of examinees, 10 something that my office and I have been very much involved 11 in. 12 And that hasn't necessarily been court work, but 13 particularly in this case where the Trustee has not had 14 financial advisors, forensic accountant professionals, where 15 we've really had to have attorneys doing that work to move 16 this investigation forward, it's taken a lot of time. It's 17 taken a lot of resources. 18 But I think that the results are evident when 19 there are adversary proceedings that are filed with initial 20 requests for injunctive relief that are supported by 21 voluminous evidence, discreet facts showing why that relief 22 is appropriate. Those facts weren't handed to us on a 23 platter. Those facts were really from the sweat of many 24 brows in the form of that investigation. 25 So particularly, I suppose for me, in addition to

Ho Wan Kwok - June 29, 2023 28 1 the work you've seen here in court because of the role as 2 conflicts counsel, obviously with a large firm like Paul 3 Hastings there are a number of examinees where we've had to 4 do, you know, grab the oar with respect to some of the 5 investigating, that's been a large part of the case. 6 And I think -- I think there have been positive 7 developments for the estate and I'm optimistic there will be 8 more positive developments for the estate. 9 So with that having been said my firm did have a 10 conversation with Attorney Claiborn for the United States 11 Trustee. Ms. Claiborn raised certain issues. We didn't 12 agree on all the issues, but we did agree that a \$10,000 13 reduction to the fee application was appropriate. That's 14 been agreed to. Otherwise I'm not aware of any objections 15 to the fee application. 16 So we would ask that the Court enter the order 17 granting the fee application. 18 To the extent the Court would be willing to do 19 that, I would suggest one of two things. 20 One, the only change to our proposed order that 21 I'm aware of is entering the date of the hearing and -- 22 THE COURT: We can take care of that. 23 MR. LINSEY: -- and reducing the number in 24 paragraphs 1 and 2 from 561,718.50 to 551,718.50. So if the 25 Court can --

Ho Wan Kwok - June 29, 2023 29 1 THE COURT: It's 10,000 even? 2 MR. LINSEY: Correct. Ten thousand even, Your 3 Honor. 4 But beyond that I'm not aware of any other changes 5 that are necessary unless the U.S. Trustee and the committee 6 have any comments with respect to our application. 7 THE COURT: The only thing I am -- 8 I'm sorry. 9 MS. CLAIBORN: Yeah. 10 THE COURT: Why don't I hear from you first, 11 Attorney Claiborn. 12 MS. CLAIBORN: I was just going to state the 13 obvious which is the U.S. Trustee is on board with the 14 \$10,000 reduction as evidenced by the statement that I filed 15 on the docket at ECF 1950. 16 And I concur with Attorney Linsey that there are 17 no other changes that need to be made to the order other 18 than to adjust the math. 19 THE COURT: Okay. Thank you. 20 Just so -- so the record is clear, what I -- what 21 I've commented on the record about the application of Paul 22 Hastings, I agree with the application, those comments are 23 applicable to the application of Neubert, Pepe & Monteith as 24 well. 25 I did review the time entries. As I said did I

Ho Wan Kwok - June 29, 2023 30 1 review every single time entry? No. But I reviewed a good 2 amount of them. And I reviewed the categories of tasks 3 performed, the amounts, the dollar amounts associated with 4 those categories. 5 It was easy for me in both situations to see where 6 the most fees were incurred, and they were incurred in 7 categories where I would think the most fees should have 8 been incurred. 9 So I, again, think the fees and expenses are 10 reasonable and absolutely necessary under the circumstances 11 of the very specific circumstances of these jointly 12 administered Chapter 11 cases, and the numerous adversary 13 proceedings, and the injunctive relief that's been sought, 14 and the issues with regard to appeals, and all the things 15 we've already talked about. 16 So I have -- again, there was nothing that stood 17 out to me as any area of concern. 18 With regard to the voluntary reduction, again, as 19 I've already said, I think those conversations are very good 20 to have. And I think that, you know, you've come to an 21 agreement. And that's fine. 22 But, again, I don't want there to be a belief that 23 that has to happen every time, with the understanding that I 24 could be the one that decides that there is a need for a 25 reduction. Okay? But I might not. You never know. You

1 just don't know. It depends upon the facts and the 2 circumstances of the case. 3 With regard to your proposed order, the only other 4 change I'm going to make, and the courtroom deputy and I can 5 do this, is I just want to cite to the statutes at the 6 beginning of the order, like the Paul Hastings' order does, 7 you know, pursuant to Sections 328, 330 and 331. 8 MR. LINSEY: I'm sorry. 9 THE COURT: That's okay. 10 MR. LINSEY: I wasn't aware that Mr. Kindseth's 11 ask applied to my firm, but I suppose it's fair. We're fine 12 doing that too. 13 THE COURT: You mean the same language that -- 14 MR. LINSEY: The same language. Would you like us

16 THE COURT: That same paragraph 4, essentially? 17 MR. LINSEY: Yeah. Okay. It's fine. 18 Would you like us to submit an order? Your Honor, 19 could -- the Court could copy and paste that language from

21 THE COURT: We can copy and paste it. 22 MR. LINSEY: Okay. 23 THE COURT: We'll keep the fees down for today as 24 much as we can. Okay? 25 MR. LINSEY: Thank you, Your Honor.

Ho Wan Kwok - June 29, 2023 32 1 THE COURT: But I -- you know, as I said, nothing 2 stood out or gave me pause in connection with these 3 applications because of the facts and circumstances that 4 we've all encountered in these cases. Okay? 5 So did the committee wish to be heard? 6 MR. GOLDMAN: Your Honor, no objection from the 7 committee for largely the same reasons articulated for Paul 8 Hastings except for the hourly rates. But we have -- we saw 9 it as Your Honor saw it. 10 THE COURT: Well, that's a reality of geography I 11 suppose. Right? As we all know. 12 But in any event we can take care of those 13 changes. 14 The Court finds that, as I said, the fees and 15 expenses are reasonable and necessary. No one has filed any 16 written objection. There's no one participating in this 17 hearing today that's objecting to the fee application. The 18 United States Trustee's Office has filed a statement of no 19 objection in connection with the agreement, further 20 reduction of the fees by \$10,000. 21 For all those reasons the application is granted 22 and the proposed order will enter. 23 MR. LINSEY: Thank you, Your Honor. 24 THE COURT: Okay. Thank you. 25 We'll make those minor changes, Attorney Linsey,

Ho Wan Kwok - June 29, 2023 33 1 that we talked about. We can do that. 2 MR. LINSEY: Thank you, Your Honor. 3 THE COURT: So, you know, again, I do think that 4 all that has occurred as far as the fees and expenses have 5 -- are reasonable and necessary and have produced results 6 for this estate which is in a very different place than it 7 was a year ago today. And that was -- 8 You know, the appointment of the Trustee was 9 designed to see if that could happen and to see if -- that 10 was the whole point. 11 All the -- the creditors had come in and said 12 there needs, you know, there needs to be an investigation, 13 there's all kinds of things going on. That was why a 14 trustee was appointed. The investigation has yielded 15 results in a -- in a very -- in less than a year, under very 16 difficult circumstances. So I -- that's very much 17 appreciated by the Court. And we'll have to see where 18 things go from here. 19 I think obviously the point of this is for the 20 benefit of creditors. 21 And so there have to be -- attorneys have to be 22 paid in order to try to reach a result that is for the 23 benefit of creditors. 24 And while the amounts may seem high I -- from July 25 8th, 2022 to February 28th, 2023, I think they're

Ho Wan Kwok - June 29, 2023 34 1 reasonable. 2 So I don't know if anyone wishes to discuss any 3 other matters today, otherwise I think -- I think we are -- 4 we do not have any further hearings in these cases until 5 July 11th, is that correct? 6 MR. DESPINS: That's my understanding, Your Honor. 7 THE COURT: Okay. All right. Well, have a nice 8 4th of July. And thank you all very much. 9 MR. DESPINS: You as well. 10 ALL COUNSEL: Thank you, Your Honor. 11 THE COURT: We do not have another matter on the 12 calendar until 12 p.m., so court is in recess until 12 p.m. 13 (Proceedings concluded at 10:51 a.m.) 14 I, CHRISTINE FIORE, court-approved transcriber and 15 certified electronic reporter and transcriber, certify that 16 the foregoing is a correct transcript from the official 17 electronic sound recording of the proceedings in the above-18 entitled matter. 19 20 21 July 7, 2023 22 Christine Fiore, CERT 23 24 25 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

--------------------------------------------------------------- x

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

--------------------------------------------------------------- x THIRD INTERIM FEE APPLICATION COVER SHEET

Interim Application of: Paul Hastings LLP

Time Period: From: July 1, 2023 To: August 31, 2023 Bankruptcy Petition Filed: February 15, 2022 (main chapter 11 case) Date of Entry of Retention Orders: August 2, 2022 [Docket No. 668] (effective as of July 8, 2022, as to Individual Debtor) and January 24, 2023 [Docket No. 1376] (effective as of October 11, 2022, as to Genever (BVI) and effective as of November 3, 2022, as to Genever (US))

Fees: \$3,725,984.25 Voluntary Fee Reductions: \$124,820.25 Expenses: \$146,137.57 Voluntary Expense Reductions: \$634.80

Fees Previously Requested: Retainer Request:

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 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 accordance with the Interim Compensation Procedures Order (as defined below), Paul Hastings previously received payments in the amount of \$1,389,424.80 and \$116,812.50 in expenses with respect to its monthly fee statement for July 2023. Paul Hastings has not received, and is currently not seeking, payment of its fees and expenses with respect to its monthly fee statement for August 2023 (although 80% of such fees and all such expenses may be paid, at a future date, in accordance with the Interim Compensation Procedures Order). In addition, while this Application seeks allowance of all fees incurred during the Fee Period, Paul Hastings is not seeking, at this time, payment of the 20% holdback with respect to the July 2023 and August 2023 fee statements.

Expenses Previously Requested: Expense Detail:

Requested Expenses: \$626,360.12 Retainer Received: Not applicable Awarded Expenses: \$626,360.12 Copies per page cost and total: \$0

Awarded Expenses: \$626,360.12 Copies per page cost and total: \$0.08 b/w (per page) Paid Expenses: \$626,360.12 \$0.20 color (per page) \$5,735.52 (total)

Expenses Fees Awarded and Paid;

Expense Reimbursement Application for the Period from July 8, 2022 through October 31, 20223

Docket No.

10/31/22 \$0.00 \$63,631.75 \$0.00 Awarded: \$63,631.75 Paid:

Special Fee Application (Sanctions) for Services Rendered in Securing Compliance with Court-Authorized Subpoenas4

Docket No.

3/10/23 \$83,370.26 \$0.00 Awarded:

Paid:

First Interim Fee Application for the Period from July 8, 2022 through February 28, 2023

Docket No.

2/28/23 \$12,326,802.00 \$348,813.54 Awarded:

Paid:

Paid:

Second Interim Fee Application for the Period from March 1, 2023 through June 30, 2023

Docket No.

credit)5 \$213,914.83 Awarded:

Paid:

Paid:

Paid:

Paid:

3 The First Interim Fee Application excluded the expense reimbursements requested in the Expense Reimbursement Application.

4 The First Interim Fee Application and the Second Interim Fee Application included the amounts sought in the Special Fee Application (for the period through February 28, 2023 and the period from March 1 - 10, 2023, respectively). Paul Hastings included these amounts not to recover twice but to ensure payment in the event the HK Parties (defined below) do not comply with the Sanctions Order (defined below). To be clear, Paul Hastings seeks to recover payment of the requested \$83,370.26 only once.

5 Due to an inadvertent oversight, the monthly fee statements for January and February 2023 (which were covered in the First Interim Fee Application) did not reflect the voluntary reduction in the hourly rate of the Trustee (from \$1,975 to \$1,860 per hour), resulting in an overstatement of Paul Hastings' fees by \$20,096.25 with respect to these two months. This amount was credited in the Second Interim Fee Application against fees requested therein.

Third Interim Fee Period from July 1, 2023 through August 31, 2023

Docket Nos.

7/31/23 \$1,389,424.80 \$116,812.50 \$1,389,424.80 \$116,812.50 \$347,356.20

Docket Nos.

8/31/23 \$1,621,148.20 \$29,325.07 \$0.00 \$0.00 \$405,287.05 Total \$3,010,573.007 \$146,137.57 \$1,389,424.80 \$116,812.50 \$752,643.25 MONTHLY FEE REQUESTS FOR THIRD INTERIM FEE PERIOD6

6 On August 18, 2023, the Court entered the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals [Docket No. 2094] (the "Interim Compensation Procedures Order"), pursuant to which estate professionals (including Paul Hastings) commenced filing monthly fee statements.

7 As detailed below, as an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of twenty one (21) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$37,232.00; however, such fees were included in the July and August fee statements filed and served on September 7, 2023 and September 20, 2023, respectively. HOURS AND RATES PER PROFESSIONAL AND PARAPROFESSIONAL DURING FEE PERIOD

Bassett, Nicholas Corporate, 2007 \$1,625.00 261.10 \$424,287.50 1 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$812.50 8.50 \$6,906.25 1 Cota, Alex Corporate, 2012 \$1,725.00 7.20 \$12,420.00 N/A Despins, Luc Restructuring, 1986 \$1,860.00 218.30 \$406,038.00 N/A Despins, Luc (travel; ½ rate) Restructuring, 1986 \$930.00 4.30 \$3,999.00 N/A

Bongartz, Alex Restructuring, 2007 \$1,625.00 172.00 \$279,500.00 1 Bongartz, Alex (travel; ½ rate) Restructuring, 2007 \$812.50 1.30 \$1,056.25 1 Luft, Avi Corporate, 2000 \$1,625.00 385.20 \$625,950.00 1 Luft, Avi (travel; ½ rate) Corporate, 2000 \$812.50 18.90 \$15,356.25 1 Traxler, Katherine Restructuring, 1990 \$1,025.00 7.40 \$7,585.00 1

Barron, Douglass Corporate, 2012 \$1,320.00 314.50 \$415,140.00 1 Catalano, Kristin Corporate, 2021 \$915.00 107.50 \$98,362.50 1 Farmer, Will Corporate, 2018 \$1,235.00 235.20 \$290,472.00 1 Ganapathi, Anuva Litigation, 2021 \$915.00 11.60 \$10,614.00 1 Grabias, Maria Corporate, 2016 \$1,290.00 16.30 \$21,027.00 N/A Kim, Sarah Litigation, 2023 \$855.00 9.10 \$7,780.50 N/A Koch, Leonie Corporate, 2023 \$855.00 9.20 \$7,866.00 1 Kosciewicz, Jon Litigation, 2021 \$915.00 102.10 \$93,421.50 1 Maza, Shlomo Corporate, 2012 \$1,320.00 152.50 \$201,300.00 1 Sadler, Tess Corporate, 2019 \$1,175.00 14.40 \$16,920.00 1 [redacted] Corporate, 2023 \$815.00 353.90 \$288,428.50 1 [redacted] (travel ½ rate) Corporate, 2023 \$407.50 7.00 \$2,852.50 1 Sutton, Ezra Corporate, 2021 \$1,015.00 307.50 \$312,112.50 1 [redacted] Corporate, 2022 \$915.00 29.40 \$26,901.00 Associate Total: 1,670.20 \$1,793,198.00

Kuo, Jocelyn Paralegal \$540.00 92.80 \$50,112.00 N/A Mohamed, David Paralegal \$540.00 184.40 \$99,576.00 1 Paraprofessional Total: 277.20 \$149,688.00

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

--------------------------------------------------------------- x

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

--------------------------------------------------------------- x THIRD INTERIM FEE APPLICATION OF PAUL HASTINGS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JULY 1, 2023 THROUGH AUGUST 31, 2023

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), Rule 2016-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Connecticut (the "Local Rules"), and the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals [Docket No. 2094] (the "Interim Compensation Procedures Order"), Paul Hastings LLP ("Paul Hastings"), as counsel to (a) Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Individual Debtor"), (b) Genever Holdings Corporation ("Genever (BVI)"), and (c) Genever Holdings LLC ("Genever (US)" and, together with Genever (BVI), the "Genever Debtors"), hereby files this Third Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the

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 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).

Period from July 1, 2023 through August 31, 2023 (the "Application"). By this Application, Paul Hastings requests allowance and payment2 of the compensation for professional services performed by Paul Hastings attorneys (including the Trustee3) and reimbursement of its actual and necessary expenses incurred during the period from July 1, 2023 through and including August 31, 2023 (the "Fee Period"). In support of this Application, Paul Hastings respectfully states as follows:

1. During the Fee Period, the Trustee and Paul Hastings continued the investigation into the financial affairs of the Individual Debtor and his corporate "shell game" to shield companies and assets under his ownership and/or control from his creditors. Given the vast network of companies affiliated with the Individual Debtor, and the fact that these companies or their assets are located around the world, the Trustee's investigation was, and continues to be, extensive. For example, to date, the Trustee's investigation has included, among other things, (a) seeking discovery under Bankruptcy Rule 2004 from hundreds of individuals and entities connected with the Individual Debtor and his various businesses, (b) analyzing thousands of documents produced in response to the Trustee's Rule 2004 subpoenas, (c) deposing several targets of the Trustee's Rule 2004 discovery, (d) interviewing former employees and business

2 In accordance with the Interim Compensation Procedures Order (as defined below), Paul Hastings previously received payments in the amount of \$1,389,424.80 and \$116,812.50 in expenses with respect to its monthly fee statement for July 2023. Paul Hastings has not received, and is currently not seeking, payment of its fees and expenses with respect to its monthly fee statement for August 2023 (although 80% of such fees and all such expenses may be paid, at a future date, in accordance with the Interim Compensation Procedures Order). In addition, while this Application seeks allowance of all fees incurred during the Fee Period, Paul Hastings is not seeking, at this time, payment of the 20% holdback with respect to the July 2023 and August 2023 fee statements.

3 In accordance with the Retention Order (as defined below), the Trustee is authorized to act as one of the attorneys for the Individual Debtor's estate, and, accordingly, this Application also seeks allowance of the Trustee's fees in such capacity. For the avoidance of doubt, in this Application, references to services provided by Paul Hastings attorneys shall include the Trustee. To be clear, time spent by the Trustee in his capacity as chapter 11 trustee, is not part of this Application, and compensation therefor will be sought by separate application.

associates of the Individual Debtor (including several communications with confidential informants), (e) researching property records, and (f) pursuing litigation to recover property of the estate.

2. In addition, during the Fee Period, as part of the Trustee's continuing efforts to recover assets for the benefit of this estate, the Trustee commenced or continued to prosecute, with the assistance of Paul Hastings, several adversary proceedings. As detailed below, in these adversary proceedings, as a result of the Trustee's and Paul Hastings' efforts during the Fee Period, the Trustee has secured numerous valuable injunctions, judgments, and settlements, as well as obtained access to tens of millions of dollars in escrow funds.

- During the Fee Period, the Trustee continued to prosecute the interpleader action commenced by U.S. Bank N.A. ("US Bank") to resolve a dispute regarding the release of \$33 million in funds (the "Escrow Funds") held by U.S. Bank. - o Shortly after the end of the Fee Period, the Court granted the Trustee's summary judgment motion and authorized the Trustee to remove the \$33 million in Escrow Funds from the segregated account and deposit such funds into the estate's general account(s). - During the Fee Period, Paul Hastings attorneys handled all matters arising out of the appeal of this Court's rulings that HK USA is an alter ego of the Individual Debtor and that the \$33 million held in escrow by U.S. Bank are property of the estate. In that appeal, the appellees, i.e., HK International Funds Investments (USA) Limited, LLC ("HK USA") and Mei Guo (i.e., the Individual Debtor's daughter), sought a stay pending appeal, which the United States District Court for the District of Connecticut (the "District Court") denied. - During the Fee Period, the Trustee, Genever (BVI), and Genever (US) reached a settlement with Bravo Luck LLC ("Bravo Luck") and the Debtors' son, Mr. Qiang Guo with respect to the adversary proceeding challenging Bravo Luck's asserted beneficial interest in the 18th floor apartment at the Sherry Netherland Hotel (the "Sherry Netherland Apartment"). As a result of the settlement, the Trustee, Genever (US) and Genever (BVI) obtained the primary relief they sought in the Bravo Luck Adversary Proceedings—namely, undisputed beneficial ownership and control of the Sherry Netherland Apartment. The settlement was approved by this Court on August 30, 2023.

- During the Fee Period, the Trustee continued to prosecute his adversary proceeding against HCHK Technologies, Inc. ("HCHK Technologies"), HCHK Property Management, Inc. ("HCHK Property"), Lexington Property and Staffing, Inc. ("Lexington Property," and, together with HCHK Technologies and HCHK Property, the "HCHK Entities"), Brian Hofmeister, in his capacity as assignee of the HCHK Entities (the "Assignee"), and certain other parties, seeking determinations that, among other things, (a) the HCHK Entities are alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets. - o The Trustee obtained Court approval of a settlement agreement (the "Assignee Settlement") between the Trustee and the Assignee pursuant to Bankruptcy Rule 9019. The Assignee Settlement provides for important benefits to the estate, including the deposit of over \$38 million of the HCHK Entities' funds into accounts controlled by the Trustee and the Assignee's commitment to not oppose the relief sought by the Trustee in the HCHK Litigation. - o The Trustee also prepared his motion for entry of a default judgment against certain defendants, which the Court granted on September 29, 2023. - On July 11, 2023, the Trustee commenced an adversary proceeding against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC, seeking determinations that, among other things, (a) the Individual Debtor is the equitable owner of a 50,000 square foot, castle-styled private residence with 12.5-acre grounds located at 675 Ramapo Valley Road, Mahwah, New Jersey 07430 (the "Mahwah Mansion"), (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to the Mahwah Mansion), and (c) that Taurus Fund is an alter ego of the Individual Debtor. - o Among other things, the Trustee obtained a preliminary injunction to protect the Mahwah Mansion. (The mansion was, and to the Trustee's knowledge, remains uninsured.) - o The Trustee reached a settlement with the U.S. Department of Justice (the "Government") to resolve certain potentially complex issues raised by the interplay of this adversary proceeding and the Government's ongoing criminal case against the Debtor currently being heard before the United States District Court for the

Southern District of New York [Case No. 23 Cr. 118 (AT)] (the "Criminal Case"). Among other things, the settlement will ensure that any proceeds from an eventual sale of the Mahwah Mansion by the Trustee (if the Trustee prevails in this adversary proceeding) are used first to pay the estate's expenses (including reasonable legal fees related to this adversary proceeding) in connection with taking control of and selling the Mahwah Mansion.

- On July 25, 2023, the Trustee commenced an adversary proceeding against Golden Spring (New York) Ltd. ("Golden Spring") and China Golden Spring Group (Hong Kong) Limited ("China Golden Spring"), seeking determinations that, among other things, (a) Golden Spring is the alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Golden Spring and/or its assets (notwithstanding China Golden Spring's purported ownership interest in Golden Spring). - o Golden Spring failed to respond to the complaint, and, on September 12, 2023, the Trustee requested entry of a default judgment as against Golden Spring. The Court entered a default judgment against Golden Spring by order dated September 20, 2023. 4 - During the Fee Period, the Trustee continued to prosecute his adversary proceeding against Greenwich Land LLC ("Greenwich Land") and the Individual Debtor's alleged wife (i.e., Hing Chi Ngok), seeking determinations that, among other things, (a) Greenwich Land (which holds legal title to the Individual Debtor's residence in Greenwich, Connecticut) is an alter ego of the Debtor and (b) the Debtor is the equitable owner of Greenwich Land. - o Following discovery in this adversary proceeding (including document discovery and depositions), the Trustee moved, on October 10, 2023, for summary judgment. - During the Fee Period, the Trustee also continued to prosecute his adversary proceeding against Mei Guo, seeking determinations that, among other things, (a) the proceeds, likely in an amount of over \$10 million, from the sale of the Individual Debtor's private Bombardier jet are property of the estate and (b) a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate.

4 On October 11, 2023, the Trustee also requested entry of a default judgment against China Golden Spring, which also failed to respond to the complaint. As of the filing of this Application, the Court has not yet ruled on that request.

3. Furthermore, during the Fee Period, the damage caused by the fire that occurred on March 15, 2023 at the Sherry Netherland Apartment continued to require the Trustee's and Paul Hastings' attention. Of particular note, during the Fee Period, Genever (US) filed its motion to (a) retain an architect, (b) authorize Genever (US) to select and hire contractors, engineers, consultants, and other third-party service providers in the ordinary course of the remediation project (including as it relates to the removal of asbestos), and (c) pay such contractors, engineers, consultants, and other third-party service providers in the ordinary course of the remediation project (including as it relates to the removal of asbestos). The Court granted the motion on September 19, 2023.

4. Concurrently with the remediation motion, the Trustee and the Genever Debtors also sought approval of interdebtor DIP financing to be provided by the Individual Debtor's estate to the Genever Debtors. As detailed in the DIP financing motion, the Genever Debtors have no cash and no source of income, and, without access to some source of liquidity, the Genever Debtors would not be able to make essential remediation repairs to the Sherry Netherland Apartment, pay current professional fees—including the costs of pursuing the AIG litigation—or even pay the statutory amounts to the U.S. Trustee, and would be forced to convert to a chapter 7 liquidation. For these reasons, the Trustee determined that the estate of the Individual Debtor would provide up to \$2,000,000 of critically necessary funding to the Genever Debtors so that they can fund their chapter 11 cases, including value-maximizing strategy for the sale of the Sherry Netherland Apartment. On September 12, 2023, the Court granted the motion.

5. All the while, during the Fee Period, the Trustee and Paul Hastings provided a wide range of other chapter 11 related services, including, for example, handling five hearings

and status conferences during the Fee Period, preparing and prosecuting numerous substantive motions and preparing monthly operating reports.

6. While the Trustee has made substantial headway in these chapter 11 cases, progress continues to be slowed by the unprecedented level of obstructionism and interference, both inside and outside the courtroom, from the Individual Debtor and his associates at every turn. This is most obvious in the Trustee's Rule 2004 investigation, where the Individual Debtor and his affiliates have continued their campaign to delay or not comply with discovery requests. And, most recently, on August 30, 2023, the Individual Debtor filed a motion (joined by Yvette Wang) in the Criminal Case seeking to stay these chapter 11 cases, pending resolution of his criminal trial.5 Other discovery targets related to the Individual Debtor also failed to comply with the Trustee's Rule 2004 subpoenas, necessitating substantial motion practice, including with respect to G-Club Operations LLC ("G-Club Operations") and Hudson Diamond NY LLC and Hudson Diamond Holding LLC (together with Hudson Diamond NY LLC, the "Hudson Entities").

7. While the Court granted substantially all of the relief requested by the Trustee (and denied substantially all of the relief requested by the Individual Debtor and his associates), the Trustee necessarily expended substantial time and resources on these matters, including because the Individual Debtor and his associates actively opposed the relief sought by the Trustee. Although it is extremely difficult to determine with precision the cost of the Individual Debtor's tactics, the Trustee continues to believe that a substantial portion of the fees generated during the Fee Period were the result of the Individual Debtor's or his affiliates' continuing non-

5 In response, Paul Hastings prepared the Trustee's emergency motion, filed on September 1, 2023 [Docket No. 2160], seeking to enjoin the Individual Debtor's stay motion on the basis that such motion violated the automatic stay in these chapter 11 cases. The Trustee and the Genever Debtors also filed a response in the Criminal Case, objecting to the imposition of a stay of these chapter 11 cases.

compliance with the Bankruptcy Code and/or active opposition or interference with the Trustee's administration of these chapter 11 cases.

8. As detailed in this Application, Paul Hastings has performed all of its services in an economic, effective, and efficient manner commensurate with the complexity and importance of the issues involved. The work performed by Paul Hastings was carefully assigned to appropriate professionals or paraprofessionals according to the experience and level of expertise required for each particular task. Whenever possible, Paul Hastings sought to minimize the costs of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. Moreover, as detailed below, Paul Hastings has delegated numerous work streams to local Connecticut counsel (which has a lower rate structure than Paul Hastings).

9. To further minimize the costs of intra-Paul Hastings communications and education about these chapter 11 cases, the Trustee utilized a small group of Paul Hastings attorneys for the majority of the work in these chapter 11 cases. Also, as a general matter, in addition to the Trustee, no more than two Paul Hastings attorneys attended the various hearings held during the Fee Period (and in some instances, the Trustee handled hearings without attendance of any Paul Hastings attorneys), thereby minimizing not only the time billed on these hearings/sessions but also the cost of travel. Furthermore, to the extent appropriate, the Trustee and Paul Hastings sought to work closely with counsel to Pacific Alliance Asia Opportunity Fund L.P. ("PAX"), including to take advantage of the knowledge of the Individual Debtor's assets and financial affairs that PAX acquired during the prepetition litigation against the Individual Debtor in New York state court (the "PAX Litigation"). Moreover, as noted on the record at the August 2, 2022 hearing on Paul Hastings' retention application, the Trustee has

agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

10. Finally, as an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of twenty one (21) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$37,232.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

11. In sum, Paul Hastings respectfully submits that the services for which it seeks compensation in this Application were necessary for and beneficial to these chapter 11 estates and their stakeholders. Accordingly, in light of the nature and complexity of these chapter 11 cases, Paul Hastings' charges for professional services performed and expenses incurred are reasonable under applicable standards. For all these reasons, Paul Hastings respectfully requests that the Court grant the Application and allow interim compensation for professional services performed and reimbursement for expenses as requested. JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

12. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut (as amended). This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

13. The legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1. Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 215 of

14. Paul Hastings believes that this Application, together with the attachments hereto,

substantially complies with the Bankruptcy Rules, Local Rule 2016-1, the Interim Compensation

Procedures Order, and the United States Trustee's Guidelines for Reviewing Applications for

Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in

Larger Chapter 11 Cases (the "U.S. Trustee Guidelines").6 Paul Hastings respectfully requests a

waiver of any of the foregoing requirements not met by this Application.

- 15. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains disclosures regarding "customary and comparable compensation." - Exhibit B1 contains a summary of Paul Hastings' timekeepers included in this Application. - Exhibit B2 contains a summary of Paul Hastings' timekeepers who billed less than five (5) hours during the Fee Period and for whom Paul Hastings is not seeking allowance or payment at this time. - Exhibit C contains a summary of the compensation requested by project category. - Exhibit D contains a summary of the compensation requested by Matter ID. - Exhibit E contains the expense reimbursements requested by category. - Exhibit F contains the monthly statements of Paul Hastings detailing the services performed and itemizing the expenses incurred during the Fee Period. - Exhibit G contains the Proposed Order.

16. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed with the

Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

6 Paul Hastings reserves all rights as to the relevance and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation in these chapter 11 cases. Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 216 of

17. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors ("Committee") in the Individual Debtor's chapter 11 case. No examiner has been appointed in the Individual Debtor's chapter 11 case.

18. On June 15, 2022, the Court entered a memorandum of decision and order [Docket No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the chapter 11 case of Ho Wan Kwok. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the chapter 11 case of Ho Wan Kwok.

19. The Court authorized Paul Hastings' retention as attorneys for the Trustee pursuant to the *Order Authorizing and Approving the Retention and Employment of Paul Hastings LLP as Counsel to Chapter 11 Trustee, effective as of July 8, 2022* [Docket No. 668] (together with the retention order with respect to the Genever Debtors [Docket No. 1376], the "Retention Order"), entered on August 2, 2022. The Retention Order authorizes Paul Hastings to be compensated on an hourly basis and reimbursed for actual and necessary out-ofpocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct. Moreover, at the August 1, 2022 hearing on the Paul Hastings' retention application, the Court made clear that it approved Paul Hastings' New York rate structure.7 In addition, as noted on the record at that hearing, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

7 See Aug. 1, 2022 H'rg Tr. at 113:15-19 ("MR. DESPINS: But I want to be clear is that that's not going to be a back door way to bring local rates, or anything like that -- THE COURT: No, I'm not doing that. I agree with that.") Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 217 of

20. In light of the Trustee's ongoing investigation into the Individual Debtor's assets and his financial affairs, the Trustee is unable at this time to predict when he will be in a position to file a plan and disclosure statement. All quarterly fees have been paid to the United States Trustee, and all monthly operating reports have been filed through August 2023 (for the Individual Debtor's chapter 11 case), July 2023 (for Genver (BVI)'s chapter 11 case), and June 2023 (for Genever (US)'s chapter 11 case).

21. At this time, the amount of cash in the Trustee's account is approximately \$75 million.8 The Trustee is not aware of any material administrative expense claims other than claims for professional fees and expenses.

22. On October 11, 2022, Genever (BVI)—an entity wholly owned by the Individual Debtor—filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

23. No trustee or official committee of unsecured creditors has been appointed in Genever (BVI)'s chapter 11 case.

24. October 14, 2022, the Court entered an order granting joint administration of the Individual Debtor's chapter 11 case and Genever (BVI)'s chapter 11 case [Docket No. 970].

25. On January 24, 2023, the Court granted Genever (BVI)'s application to retain Paul Hastings as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., October 11, 2022 [Docket No. 1376].

8 This amount includes approximately \$38.8 million in funds received and held by the Trustee pursuant to the settlement with the Assignee in the HCHK Adversary Proceeding (as defined below). Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 218 of

26. On October 12, 2020, Genever Holdings LLC—an entity wholly owned by Genever (BVI)—filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code in the United States Bankruptcy Court for the Southern District of New York (the "SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG) (the "SDNY Bankruptcy Case").

27. On November 3, 2022, the SDNY Bankruptcy Court entered an order [Docket No. 225 in Case No. 22-50592] transferring the venue of the SDNY Bankruptcy Case to this Court, which assigned it Case Number 22-50592.

28. On November 21, 2022, the Court entered an order granting joint administration of the Genever (US) Debtor's chapter 11 case with the jointly administered cases of the Individual Debtor and the Genever (BVI) Debtor's chapter 11 case [Docket No. 1141].

29. On January 24, 2023, the Court granted Genever (US)'s application to retain Paul Hastings as counsel to Genever (US) in its chapter 11 case, effective as of the order transferring venue of the SDNY Bankruptcy Case to this Court, i.e., November 3, 2022 [Docket No. 1376].

30. By this Application, the Trustee and Paul Hastings request allowance of fees (in the amount of \$2,980,787.40) and expenses incurred (in the amount of \$146,137.57) for services rendered by, for, and on behalf of the Trustee during the Fee Period.9 The Trustee has approved the amounts requested by Paul Hastings herein.

9 As an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of twenty one (21) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$37,232.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

31. While this Application seeks allowance of all fees incurred during the Fee Period,

Paul Hastings does not seek, at this time, payment of the 20% holdback withheld by the Debtors'

estates with respect to Fee Period. Moreover, as noted, Paul Hastings has not been paid with

respect to its monthly fee statement for the month of August 2023 (and does not seek payment of

such fees at this time). That said, and for the avoidance of doubt, 80% of the fees for the month

of August and all such expenses may be paid, at a future date, in accordance with the Interim

Compensation Procedures Order.

32. To date, the Trustee and Paul Hastings have submitted the following fee/expense-

related applications in these chapter 11 cases:

- (a) On March 1, 2023, Paul Hastings submitted the *First Interim Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Reimbursement of Expenses for the Period from July 8, 2022 through October 31, 2022* [Docket No. 1495] (the "Expense Reimbursement Application"), whereby the Trustee and Paul Hastings requested reimbursement of the actual and necessary expenses incurred by the Trustee and Paul Hastings during the period from July 8, 2022 through October 31, 2022 in the amount of \$63,631.75. On May 3, 2023, the Court entered an order granting the Expense Reimbursement Application [Docket No. 1747] (the "Expense Reimbursement Order"). The Individual Debtor's estate paid the foregoing amount on May 8, 2023. - (b) On April 10, 2023, Paul Hastings submitted the *Special Fee Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Services Rendered in Securing Compliance with Court-Authorized Subpoenas* [Docket No. 1648] (the "Special Fee Application"). In the Special Fee Application, Paul Hastings requested allowance and payment of fees in the amount of \$83,370.26 in accordance with the HK Parties Contempt Order.10 On April 21, 2023, the Court approved

10 On March 10, 2023, the Court entered the *Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC* [Docket No. 1537] (the "HK Parties Contempt Order"), pursuant to which the Court ordered Ms. Mei Guo, HK USA, attorney Lee Vartan, and Chiesa Shahinian & Giantomasi PC (collectively, the "HK Parties"), jointly and severally, to compensate the Trustee and his counsel, Paul Hastings, for reasonable attorneys' fees and expenses associated with the Trustee's efforts to secure compliance with certain Court-authorized subpoenas.

the Special Fee Application and ordered the HK Parties to remit payment of \$83,370.26 to the chapter 11 estate of the Individual Debtor [Docket No. 1693] (the "HK Parties Sanctions Order"). As of the filing of this Application, the HK Parties have not remitted payment.

- (c) On May 30, 2023, Paul Hastings submitted the *Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 8, 2022 through February 28, 2023* [Docket No. 1831] (the "First Interim Fee Application") seeking \$12,326,802.00 in fees and \$348,813.54 for reimbursement of expenses. The First Interim Fee Application excluded the expense reimbursements approved in the Expense Reimbursement Order. The First Interim Fee Application included the amount requested in the Special Fee Application (for the period through February 28, 2023). However, to the extent the Trustee is able to recover the fees under the HK Parties Sanctions Order from the HK Parties, Paul Hastings will not seek payment of such fees from these estates.11 Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$550,000. On June 29, 2023, the Court approved the First Interim Fee Application [Docket No. 1964] with such reduction. Paul Hastings has received payment of \$11,776,802.00 in fees and \$348,813.54 in expenses in connection with the First Interim Fee Application. - (d) On August 4, 2023, Paul Hastings submitted the *Second Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from March 1, 2023 through June 30, 2023* [Docket No. 2051] (the "Second Interim Fee Application") seeking \$8,037,720.00 in fees and \$213,914.83 for reimbursement of expenses. The Second Interim Fee Application included the amount requested in the Special Fee Application (for the period from March 1, 2023 through March 10, 2023). However, to the extent the Trustee is able to recover the fees under the HK Parties Sanctions Order from the HK Parties, Paul Hastings will not seek payment of such fees from these estates. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$55,000.00. On September 12, 2023, the Court approved the Second Interim Fee Application [Docket No. 2190] with such reduction. Paul Hastings has received payment of \$6,386,176.00 in fees (or 80% of the allowed fees

11 At this time, the HK Parties have not paid the amounts due under the HK Parties Sanctions Order (even though such amounts were due on May 5, 2023). Indeed, the HK Parties have (unsuccessfully) sought reconsideration of the HK Parties Sanctions Order [Docket Nos. 1730 and 1733] and, thereafter, appealed both the HK Parties Sanctions Order and the order denying reconsideration [Docket No. 1750], as well as sought a stay pending appeal [Docket No. 1770]. That request for a stay was denied by order dated May 15, 2023 [Docket No. 1791]. That said, the Trustee agreed not to seek to enforce the Sanctions Order pending the District Court's decision on the appeal.

in the amount of \$7,982,720) and \$213,914.83 in expenses in connection with the Second Interim Fee Application.

(e) In September 2023, pursuant to the Interim Compensation Procedures Order, Paul Hastings submitted monthly fee statements for services rendered during the Fee Period. See Docket Nos. 2180 and 2228 for July 2023 services and Docket Nos. 2218 and 2228 for August 2023 services. Paul Hastings requested (i) for July 2023 services, fees in the amount of \$1,389,424.80 (i.e., 80% of \$1,736,781.00 in fees incurred) and \$116,812.50 in expenses and (ii) for August 2023 services, fees in the amount of \$1,621,148.20 (i.e., 80% of \$2,026,435.25 in fees incurred) and \$29,325.07 in expenses. Paul Hastings has received payment in the amount of \$1,389,424.80 with respect to its July 2023 services. As noted, Paul Hastings has not received payment with respect to its August 2023 services.

33. Except as set forth above, neither the Trustee nor Paul Hastings has received any payment or promise of payment from any source for services rendered during the Fee Period. There is no agreement or understanding between the Trustee and/or Paul Hastings and any other person other than the attorneys, employees, and staff of Paul Hastings, for the sharing of compensation to be received for services rendered in these chapter 11 cases.

34. Paul Hastings' professional services during the Fee Period required an aggregate expenditure of 3,031.60 recorded hours by attorneys and paraprofessionals, broken down as follows: partners (499.40 hours), of counsel (584.80 hours), associates (1,670.20 hours), and paraprofessionals (277.20 hours). The timekeepers who rendered such services are identified in the Cover Sheet hereto, along with the number of hours and the total compensation sought for each individual.

35. Paul Hastings maintains computerized records, in the form of monthly statements, of the time spent by all Paul Hastings' attorneys and paraprofessionals in connection with its representation of the Trustee and the Genever Debtors. With the exception of the monthly

statements submitted with the Special Fee Application,12 the monthly statements are in the same form regularly used by Paul Hastings to bill its clients for services rendered and include the date that the services were rendered, a detailed, contemporaneous narrative description of the services provided, the amount of time spent for each service, and the designation of the professional who performed the service. Attached hereto as Exhibit F are true and correct copies of the monthly statements of Paul Hastings related to the fees requested herein.

36. As a courtesy to these estates and based on circumstances unique to these chapter 11 cases, Paul Hastings did not implement the August 1, 2023 firm-wide hourly rate increase in these chapter 11 cases and, instead, maintained the existing rates for the Fee Period. 13 In addition, Paul Hastings agreed on a reduced hourly rate for Luc Despins (from his standard hourly rate of \$1,975 to the reduced hourly rate of \$1,860) for the Fee Period.14 Other than these hourly rate discounts, the rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. In addition, when Paul Hastings' restructuring professionals and paraprofessionals work on non-bankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable non-bankruptcy cases in a competitive national legal market.

37. Paul Hastings respectfully submits that the reasonable value of the services rendered by Paul Hastings (including the Trustee) during the Fee Period is \$3,725,984.25.

12 As noted in the Special Fee Application, Paul Hastings' monthly statements for fees incurred in securing compliance with the Court-authorized subpoenas are limited to those services and, thus, vary in form from that regularly used by Paul Hastings to bill its clients for services rendered.

13 This translates into a voluntary waiver of \$62,236.50 in fees.

14 This translates into a voluntary waiver of \$25,351.75 in fees.

38. During the Fee Period, Paul Hastings assisted and advised the Trustee and the Genever Debtors on a regular basis regarding legal matters relating to these chapter 11 cases and the pursuit and recovery of estate assets for the benefit of the chapter 11 estates and their creditors. In addition, Paul Hastings prepared various motions, applications, proposed orders, and other pleadings submitted to the Court for consideration, and performed the necessary professional services that are described below and in the fee statements attached hereto and incorporated herein by reference. 15

39. For ease of reference and transparency purposes, and at the request of the U.S.

Trustee, Paul Hastings created the following separate Matter IDs for services in these chapter 11 cases, including separate Matter IDs for the major adversary proceedings pending in these chapter 11 cases. 16

00001 General Chapter 11 Trustee Representation 00002 Asset Recovery Investigation and Litigation

15 The description of services in this Application is limited to those matters in which Paul Hastings provided five (5) or more hours of service during the Fee Period.

16 These new Matter IDs (i.e., 00012 through 00022) were established effective as of March 1, 2023.

17 Not included as part of this Application.

40. Additionally, the Trustee and the Genever Debtors retained Neubert Pepe &

Monteith, P.C. ("NPM") as their local and conflicts counsel in order to provide services to the

Trustee and the Genever Debtor's estates in a cost-effective manner. In particular, as detailed in

the NPM retention application and related declarations, Paul Hastings and NPM have

coordinated, and will continue to coordinate, each firm's respective responsibilities in connection

with the representation of the Trustee and the Genever Debtors. Among other things, during the

Fee Period, the following matters were delegated to NPM:

- Assisting with filings and service of pleadings in the main chapter 11 case and related adversary proceedings; - Preparing supplemental motions for discovery under Bankruptcy Rule 2004 (including for discovery targets for which Paul Hastings is conflicted), conducting meet and confers with discovery targets, and reviewing documents produced in response to Rule 2004 subpoenas; - Assisting the Trustee on matters on which Paul Hastings is conflicted; - Preparing certain procedural motions, including motion to seal, motions to expedite, and motions to adjourn; - Advising the Trustee and the Genever Debtors on matters related to local Connecticut rules; - Preparing monthly operating reports for the Genever Debtors; and - Performing a variety of case administration functions, including interacting with the Court and the clerks' office as needed, preparing

18 Not included as part of this Application.

certificates of service, coordinating logistics for hearings, and handling other case administration functions as they arise from time to time.

41. In addition, Paul Hastings has recently also delegated a number of important

matters (including entire adversary proceedings) related to the Trustee's investigation and efforts to recover assets for the benefit of these estates. I. General Chapter 11 Trustee Representation (Matter ID 00001)

- A. Case Administration (Task Code B110) Fees: \$73,188.50 Total Hours: 80.80 - 42. During the Fee Period, Paul Hastings attorneys handled numerous case

administrative matters in connection with these chapter 11 cases, including (a) developing shortterm and long-term strategies for recovering assets for the benefit of these estates, (b) maintaining a case calendar and task lists of open matters and work streams, (c) handling various logistical matters (including as it relates to the Trustee's bank accounts), (d) handling numerous calls and correspondence with the U.S. Trustee and PAX regarding the background to, and the administration of, these chapter 11 cases, and (e) holding internal team meetings and calls to coordinate work streams.

B. Pleadings Review (Task Code B113) Fees: \$47,416.50 Total Hours: 86.00

43. During the Fee Period, Paul Hastings attorneys reviewed and monitored the docket of these chapter 11 cases, the related adversary proceedings, and pending state court litigation, as well as reviewed pleadings filed therein, as necessary.

C. Court Hearings (Task Code B155) Fees: \$16,528.50 Total Hours: 28.80

44. During the Fee Period, Paul Hastings attorneys prepared for and attended numerous hearings and status conferences. As detailed below, most of the hearings were recorded under the applicable Matter ID. That said, general hearing preparation (including

agendas) for the hearings scheduled on July 11, 2023, July 18, 2023, August 15, 2023, August 22, 2023, and August 29, 2023 was recorded under Matter ID 00001.

D. Fee / Employment Applications for Paul Hastings (Task Code B160) Fees: \$148,148.50 Total Hours: 103.60

45. During the Fee Period, in connection with Paul Hastings' retention, Paul Hastings attorneys prepared a supplemental declaration with respect to the Trustee's and Paul Hastings' disinterestedness [Docket No. 2204] and conducted related research to identify possible connections between the Trustee and Paul Hastings, on the one hand, and parties in interest in these chapter 11 cases, on the other hand. In addition, Paul Hastings attorneys assisted NPM in preparing (a) the *Motion of Chapter 11 Trustee and Genever Debtors for Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals* [Docket No. 2002] (which the Court granted on August 18, 2023 [Docket No. 2094]), (b) the Second Interim Fee Application [Docket No. 2051] (which the Court granted on September 12, 2023 [Docket No. 2190]), (c) Paul Hastings' monthly fee statements for services rendered in March, April, May, June, and July 2023, and (d) portions of this Application. Paul Hastings also corresponded and engaged in discussions with the U.S. Trustee to address questions regarding the above fee and expense reimbursement requests. Among other things, Paul Hastings consensually resolved the U.S. Trustee's informal comments to the Second Interim Fee Application. E. Fee / Employment Applications for Other Professionals (Task Code B165) Fees: \$56,220.00 Total Hours: 36.60

46. During the Fee Period, Paul Hastings attorneys interviewed potential candidates to serve as forensic accountants and, upon the Trustee's selection of Kroll, LLC ("Kroll") as forensic accountant, assisted Kroll in the preparation of its application to be retained by the

Trustee as forensic accountant [Docket No. 2162] (which application was granted by order, dated September 29, 2023 [Docket No. 2241]). Paul Hastings attorneys also assisted various other estate professionals in connection with their retention applications, including the application to retain Bohonnon Law Firm, LLC, as special maritime counsel in connection with the sale(s) of the Lady May and Lady May II [Docket No. 2025] (which application was granted by order, dated August 18, 2023 [Docket Nos. 2095]).

47. In addition, during the Fee Period, Paul Hastings attorneys handled various other fee-related issues, including (a) assisting Epiq Corporate Restructuring, LLC ("Epiq") with its interim fee application, (b) assisting Engineering Operations and Certification Services, LLC ("EOCS") with respect to its invoice related to the transition of ownership of the Lady May to the Trustee, and (c) assisting Harney Westwood and Riegels LP ("Harney Legal") and Pallas Partner LLP ("Pallas") with their monthly fee statements.

F. Business Operations (Task Code B210) Fees: \$16,946.00 Total Hours: 12.70

48. During the Fee Period, Paul Hastings attorneys assisted the Trustee with various matters related to the operation of these chapter 11 estates, including handling wire transfers and obtaining an updated trustee bond.

G. Financial Reports (Monthly Operating Reports) (Task Code B211) Fees: \$9,267.00 Total Hours: 8.00

49. During the Fee Period, Paul Hastings attorneys prepared the monthly operating reports in the Individual Debtor's chapter 11 case. In the interest of minimizing costs, the monthly operating reports for the Genever Debtors were prepared by NPM, and any time spent by Paul Hastings attorneys reviewing and commenting such reports was recorded under Matter ID 00010 (for Genever (US)) and 00011 (for Genever (BVI)). H. Financing/Cash Collections (Task Code B230) Fees: \$225,833.00 Total Hours: 174.00

50. During the Fee Period, Paul Hastings attorneys prepared the Trustee and the Genever Debtors' motion seeking approval of interdebtor DIP financing to be provided by the Individual Debtor's estate to the Genever Debtors [Docket No. 2110], including the related DIP financing agreement. As detailed in the DIP financing motion, the Genever Debtors are in a precarious position in their chapter 11 cases. The current condition of the Sherry Netherland Apartment is such that it is uncertain if, and when, Genever (US) will be able to rent or sell the property. And while Genever (US) believes it will prevail in its litigation against AIG regarding the insurance coverage with respect to the Sherry Netherland Apartment, the outcome of that litigation is also uncertain. At the same time, the Genever Debtors have no cash and no source of income. Without access to some source of liquidity, the Genever Debtors would not be able to make essential remediation repairs to the Sherry Netherland Apartment, pay current professional fees—including the costs of pursuing the AIG litigation—or even pay the statutory amounts to the U.S. Trustee, and would be forced to convert to a chapter 7 liquidation. For these reasons, the Trustee determined that the estate of the Individual Debtor would provide up to \$2,000,000 of critically necessary funding to the Genever Debtors so that they can fund their chapter 11 cases while they pursue a chapter 11 process—including pursuing the AIG litigation and a valuemaximizing strategy for the sale of the Sherry Netherland Apartment.

51. Before filing the DIP financing motion, the Trustee and Paul Hastings engaged in discussions with the Sherry Netherland and the U.S. Trustee and resolved their concerns with respect to the DIP financing motion. As a result, no objections were filed to the DIP financing motion, and, on September 12, 2023, the Court entered an order granting the motion [Docket No. 2193]. II. Asset Recovery Investigation and Litigation (Matter ID 00002)*19*

- I. Court Hearings (Task Code B155) Fees: \$33,105.00 Total Hours: 29.10 - 52. During the Fee Period, Paul Hastings attorneys attended numerous hearings

related to the Trustee's investigation and related litigation, including:

- the July 11, 2023 hearing on, among other things, (a) the Trustee's motion to compel compliance with Rule 2004 subpoenas as it pertains to certain Hudson Diamond entities, (b) Zeisler & Zeisler's motion to withdraw as counsel to Hudson Diamond NY LLC, and (c) Genever (US)'s application to retain Affiliated Adjustment Group, Ltd. ("AAGL"), as public adjuster. - the July 18, 2023 hearing on, among other things, the Trustee's omnibus motion to compel compliance with Rule 2004 subpoenas as it pertains to GTV Media, Inc., Saraca Media Group, Inc. and attorney Aaron D. Mitchell; and - the August 22, 2023 hearing on the Trustee's omnibus motion to compel compliance with Rule 2004 subpoenas as it pertains to certain Hudson Diamond entities. - 53. In addition, general hearing preparation (including agendas) for the hearings

scheduled on July 11, 2023, July 18, 2023, August 15, 2023, August 22, 2023, and August 29,

2023 was also recorded under Matter ID 00002.

- J. General Litigation (Task Code B191) Fees: \$43,667.50 Total Hours: 36.70 - 54. During the Fee Period, Paul Hastings attorneys worked on several litigation

matters not related to a specific adversary proceeding,20 including (i) holding several internal

19 As part of the consensual resolution of the U.S. Trustee's informal comments to Paul Hastings' First Interim Fee Application, Paul Hastings agreed that, effective March 1, 2023, time spent on the key adversary proceedings in these chapter 11 cases would be recorded under separate matter numbers, namely Matter IDs 00012 to 00022 (as opposed to Matter ID 00002). Only litigation work not related to specific adversary proceedings continues to be recorded under Matter ID 00002, Task Code B191 (General Litigation). This change does not affect the other work streams recorded under Matter ID 00002.

20 As noted, effective as of March 1, 2023, Paul Hastings has recorded time spent on the key adversary proceedings in these chapter 11 cases under separate matter numbers, as detailed below.

calls to discuss general litigation strategy and next steps, (ii) maintaining a task list with respect to pending adversary proceedings, (iii) maintaining a tracking chart with respect to the pending appeals in these cases, and (iv) generally reviewing and analyzing pleadings filed in adversary proceedings. K. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$7,438.75 Total Hours: 10.90

55. During the Fee Period, Paul Hastings attorneys traveled to (a) the Federal Courthouse in Bridgeport, Connecticut, for various hearings and (b) Connecticut to conduct depositions in connection with the Trustee's Rule 2004 investigation.

L. Investigations (Task Code B261) Fees: \$542,440.50 Total Hours: 451.00

56. During the Fee Period, Paul Hastings attorneys continued to handle the Trustee's extensive investigation to identify potential assets of the Individual Debtor's estate. Given the corporate maze of shell companies set up by the Individual Debtor, including hundreds of companies purportedly owned by his close family members, business associates, and employees, this investigation has necessarily been extensive and time intensive.

57. As part of this investigation, Paul Hastings attorneys (a) analyzed documents produced in response to Rule 2004 subpoenas,21 (b) engaged in meet and confer sessions with the targets of the Rule 2004 discovery, (c) identified additional entities for further investigation, (d) interviewed potential forensic accountants, (e) conducted numerous calls and meetings with the forensic accountant (Kroll) to apprise them of the status of the Trustee's investigation, (f) analyzed various issues related to Zeisler & Zeisler's motion to withdraw as counsel to Hudson

21 As further detailed below, in the interest of minimizing costs, Paul Hastings utilized UnitedLex Corporation ("UnitedLex") to conduct, among other things, first-round review of documents produced in the Trustee's investigation. UnitedLex specializes in discovery services, including document processing, storage, review services, and distribution.

Diamond NY LLC, and (g) analyzed potential claims against the Individual Debtor and his affiliated entities (including potential claims under RICO). In addition, Paul Hastings attorneys prepared for and deposed (i) M. Levine of Elliot Kwok Levine & Jaroslaw LLP, which was counsel to Lamp Capital LLC between May 2022 and September 2022, and (ii) J. Siegal of Baker & Hostetler LLP, which was counsel to the Debtor between September 2020 and on or around February 2022.

58. Paul Hastings attorneys also continued to assist NPM in preparing supplemental motions under Bankruptcy Rule 2004 seeking discovery from various individuals and entities associated with the Individual Debtor, including the motion filed on August 11, 2023 [Docket No. 2079] and the related reply brief filed on August 25, 2023 [Docket No. 2145] in response to the objection filed by Greenwich Land, LLC ("Greenwich Land") and Hing Chi Ngok [Docket No. 2098].22 The Court overruled the objection and granted the supplemental Rule 2004 motion by orders dated September 19, 2023 [Docket No. 2210]. In addition, on August 11, 2023, Paul Hastings filed the Trustee's supplemental motion to hold GTV Media Group, Inc. and Saraca Media Group, Inc. in civil contempt for failing to respond to the Trustee's Rule 2004 subpoenas [Docket No. 2080], which motion was granted by order dated August 18, 2023 [Docket No. 2093]. Furthermore, during the Fee Period, Paul Hastings attorneys communicated with confidential informants, who provided valuable insight into the Individual Debtor's business operations.23

22 The supplemental Rule 2004 motion was filed by NPM because Paul Hastings was conflicted as to some of the discovery targets. To the extent Paul Hastings did not have a conflict, it assisted NPM in preparing the supplemental motion.

23 In light of the Individual Debtor's well-documented social media campaign against the Trustee, Paul Hastings attorneys, and creditors in these chapter 11 cases, the time entries attached to this Application have been redacted to remove the names of these "tipsters."

59. As noted in Paul Hastings' prior fee applications, much of the Trustee's investigation also required the expertise of Paul Hastings' Mandarin-speaking attorneys in order to analyze thousands Mandarin-language documents (including WhatsApp, text messages, and videos). This work required not only Mandarin language skills but an understanding of the legal significance of these documents, which an outside translation service would not be able to provide. Paul Hastings' Mandarin-speaking attorneys were also critical for the Trustee to communicate with the numerous Mandarin-speaking "informants" that have reached out to the Trustee during the course of these chapter 11 cases.

60. To date, the Trustee's investigation (including as a result of discovery under Rule 2004, information provided by confidential informants, and corporate documents received from BVI registered agents) uncovered numerous assets that the Trustee believes are property of the Individual Debtor's estate, which the Trustee is seeking to recover for the benefit of the estate. In fact, as detailed further below, during the Fee Period, the Trustee continued to prosecute several adversary proceedings to recover such assets.

61. Unfortunately, as the Court is well aware, the Trustee's investigation continued to face vigorous opposition, at every turn, not only from the Individual Debtor, but also many of the targets of the Trustee's investigation (i.e., the Individual Debtor's close family members, business associates, and employees), necessitating significant motion practice to compel compliance (which compliance, to this day, remains forthcoming in many instances). For example, on July 26, 2023, the Court entered an order [Docket No. 2035] (the "Contempt Order") granting the Trustee's motion to hold the Individual Debtor in contempt for improperly

asserting his Fifth Amendment right against self-incrimination to refuse to produce documents to the Trustee.24

62. On March 10, 2023, the Court entered the HK Parties Contempt Order [Docket No. 1537] holding the HK Parties (i.e., HK USA, Ms. Guo, and attorney Lee Vartan) in contempt and directing them, jointly and severally, to compensate the Trustee and his counsel, Paul Hastings, for reasonable attorneys' fees and expenses associated with the Trustee's efforts to secure compliance with the subpoenas. On April 10, 2023, the Trustee and Paul Hastings filed their Special Fee Application seeking payment of \$83,370.26 from the HK Parties with respect to fees incurred during the period from September 28, 2023 through March 10, 2023 (i.e., the date the Court entered the HK Parties Contempt Order). The Court granted the Special Fee Application by order dated April 23, 2023 [Docket No. 1693], i.e., the HK Parties Sanctions Order.

63. All of the fees covered by the Special Fee Application were incurred prior to the Fee Period (i.e., prior to July 1, 2023). 25 However, Paul Hastings has continued to track time spent on these matters after March 10, 2023 under Task Code B262, which time principally relates to the HK Parties' appeal of the HK Parties Sanctions Order.26 Among other things,

M. Contempt Proceedings (Task Code B262) Fees: \$7,897.50 Total Hours: 5.10

24 As the Trustee advised the Court at the September 27, 2023 hearing that, at the request of the Government, the Trustee is presently not pursuing the documents at issue in the Contempt Order.

25 As detailed in the Special Fee Application, the time spent on seeking to compel HK USA and Ms. Guo to comply with the Trustee's subpoenas was recorded under Task Code B262 (with a 50% reduction to reflect that some of that time also related to the enforcement of the subpoena issued to the Individual Debtor).

26 Prior to the Fee Period, the HK Parties unsuccessfully sought reconsideration of the HK Parties Sanctions Order [Docket Nos. 1730 and 1733] and, thereafter, appealed both the HK Parties Sanctions Order and the order denying reconsideration [Docket No. 1750], as well as sought a stay pending appeal [Docket No. 1770]. That request for a stay was denied by order dated May 15, 2023 [Docket No. 1791]. That said, the Trustee agreed not to seek to enforce the Sanctions Order pending the District Court's decision on the appeal.

during the Fee Period, Paul Hastings attorneys prepared the Trustee's appellee brief in this appeal. III. Other Litigation (Matter ID 00003) *27* N. General Litigation (Task Code B191) Fees: \$53,166.00 Total Hours: 39.20

64. During the Fee Period, Paul Hastings attorneys assisted the Trustee on various litigation-related matters (other than the adversary proceedings pending in these chapter 11 cases). First, as the Court is well aware, on March 15, 2023, the Individual Debtor and Yvette Wang were arrested by federal law enforcement authorities. Paul Hastings monitored these criminal proceedings and reviewed pleadings filed in these proceedings.

65. Moreover, on August 30, 2023, the Individual Debtor filed a motion (joined by Yvette Wang) in the Criminal Case seeking to stay these chapter 11 cases, pending outcome of his criminal trial. In response, Paul Hastings prepared the Trustee's emergency motion, filed on September 1, 2023 [Docket No. 2160], seeking to enjoin the Individual Debtor's stay motion on the basis that such motion violated the automatic stay in these chapter 11 cases.28

A. Asset Disposition (Task Code B130) Fees: \$10,150.50 Total Hours: 7.50

66. During the Fee Period, Paul Hastings attorneys and the Trustee, in close coordination with Edmiston, handled all aspects of the sale and marketing process for the Lady May II, as well as certain post-closing matters with respect to the sale of the Lady May (the sale

27 As a general matter, time spent on litigation-related tasks other than adversary proceedings in these chapter 11 cases was tracked under Matter ID 00003.

28 By order dated September 12, 2023 [Docket No. 2195], the Court denied the Trustee's related motion to expedite his emergency motion, noting that a hearing, if any, on the emergency motion would be scheduled after the district court presiding over the Criminal Case has acted on the Individual Debtor's stay motion.

of which closed on June 30, 2023, i.e., immediately prior to the Fee Period). In addition, during the Fee Period, Paul Hastings began analyzing various issues related to the potential sale of furniture located at the Sherry Netherland Apartment.

A. Sale of Real Estate (Task Code B131) Fees: \$10,621.00 Total Hours: 8.20

67. During the Fee Period, Paul Hastings attorneys continued to analyze numerous issues related to the sale process for the Sherry Netherland Apartment. While the sale process was necessarily put on hold following the March 15, 2023 fire in order to assess the damage to the Sherry Netherland Apartment and evaluate the sale strategy going forward, Paul Hastings continued to analyze certain legal issues pertaining to an eventual sale of the apartment, including as to the treatment of co-op leases in bankruptcy.

B. Fee / Employment Applications for Other Professionals (Task Code B165) Fees: \$18,250.00 Total Hours: 11.40

68. During the Fee Period, Paul Hastings attorneys assisted Genever (US)'s public adjuster, i.e., AAGL, in connection with the March 15, 2023 fire at the Sherry Netherland apartment [Docket No. 1749], which application was granted on July 13, 2023 [Docket No. 2000]. Paul Hastings attorneys also prepared and filed the application of O'Sullivan McCormack Jensen & Bliss PC ("OMJB"), as special insurance coverage counsel to Genever (US) [Docket No. 2042], which application was granted on August 22, 2023 [Docket No. 2105]. 29 OMJB represents Genever (US) in its adversary proceeding seeking, among other things, an injunction prohibiting AIG from cancelling certain AIG insurance policies sold to Genever (US) with respect to the Sherry Netherland Apartment.

29 OMJB replaced Saxe Doernberger & Vita, P.C. as special insurance coverage counsel. C. Other Contested Matters (Task Code B190) Fees: \$69,610.50 Total Hours: 54.80

69. During the Fee Period, Paul Hastings attorneys prepared Genever (US)'s motion to remediate the area of the Sherry Netherland Apartment affected by the March 15, 2023 fire. As detailed in the remediation motion, the March 15, 2023 fire (including the fire department's efforts to extinguish the fire and law enforcement's investigation into the cause of the fire) has caused significant damage to an area of approximately 2,000 square free of the apartment, leaving the apartment, for all practical purposes, in an unmarketable condition.

70. In the remediation motion, Genever (US) requested entry of an order (a) approving Genever (US)'s entry into, and performance under, into an agreement with Acheson Doyle, as architect, (b) authorizing Genever (US) to select and hire contractors, engineers, consultants, and other third-party service providers in the ordinary course of the remediation project (including as it relates to the removal of asbestos), as may be necessary to remediate the area affected by the fire, subject to certain procedures detailed in the motion, and (c) pay such contractors, engineers, consultants, and other third-party service providers in the ordinary course of the remediation project (including as it relates to the removal of asbestos).

71. In connection with preparing the remediation motion, Genever (US) and Paul Hastings also closely coordinated with, among others, the Sherry Netherland, PAX, and the U.S. Trustee. No objections were filed to the remediation motion, and, by order dated September 19, 2023 [Docket No. 2213], the Court granted the motion. D. Business Operations (Task Code B210) Fees: \$32,054.50 Total Hours: 19.60

72. During the Fee Period, Paul Hastings attorneys analyzed various operational matters with respect to Genever (US), including, most notably, as it relates to the remediation

project for the Sherry Netherland Apartment following the March 15, 2023 fire. In this regard, the Trustee had numerous communications with the architect (Acheson Doyle), counsel to the Sherry Netherland, and counsel to the insurer (AIG).

- A. Court Hearings (Task Code B155) Fees: \$47,789.50 Total Hours: 31.10 - 73. During the Fee Period, Paul Hastings attorneys attended numerous hearings

related to the Mahwah Adversary Proceeding (as defined below), including:

- the August 14, 2023 hearing on the Trustee's motion seeking a preliminary injunction; and - the August 29, 2023 hearing on the Trustee's motion seeking approval of the settlement with the U.S. Department of Justice. - B. General Litigation (Task Code B191) Fees: \$353,192.50 Total Hours: 292.10

74. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC [Adv. Proc. No. 23-05017] (the "Mahwah Adversary Proceeding").30 In the Mahwah Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the Debtor is the equitable owner of the 50,000 square foot Mahwah Mansion, (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to Mahwah Mansion), and (c) that Taurus Fund is an alter ego of the Individual Debtor.

75. In addition to preparing the complaint, Paul Hastings attorneys prepared, among other things, a motion for a temporary restraining order and preliminary injunction and related pleadings, as well as a motion to seal the filing of the complaint pending the entry of the

30 The Mahwah Adversary Proceeding was commenced on July 11, 2023.

temporary restraining order. Injunctive relief and keeping the complaint temporarily under seal were necessary in order to protect the Mahwah Mansion and avoid potential damage or other issues that could arise had the complaint been filed publically. On August 1, 2023, the Court granted the motion to seal [Docket No. 16 in Adv. Proc. No. 23-05017] and entered a temporary restraining order [Docket No. 17 in Adv. Proc. No. 23-05017]. In addition, on August 24, 2023, the Court granted the requested preliminary injunction [Docket No. 47 in Adv. Proc. No. 23- 05017]. After the Trustee learned that the Mahwah Mansion was not insured, Paul Hastings attorneys prepared and filed an emergency motion [Docket No. 57 in Adv. Proc. No. 23-05017] seeking to modify the preliminary injunction to further limit access to the property to certain authorized parties. The Court granted the requested modification by order dated August 31, 2023 [Docket No. 58 in Adv. Proc. No. 23-05017].

76. Furthermore, during the Fee Period, Paul Hastings attorneys prepared the Trustee's motion seeking approval of a settlement with the Government to resolve certain potentially complex issues raised both the Mahwah Adversary Proceeding and in the Government's ongoing criminal case against the Debtor currently being heard in the Criminal Case, with respect to the Debtor's Mahwah Mansion.

77. As detailed in the settlement motion, the Mahwah Mansion has become a target for the Government in the Criminal Case because the Government alleges that the Mahwah Mansion is subject to forfeiture because it was purchased with the proceeds of the Debtor's alleged criminal schemes, and that its value should be distributed to the victims of such crimes as restitution. The proposed settlement effectuates a preliminary resolution to the issues surrounding the Mahwah Mansion. Under the Settlement Agreement, the Government has agreed not to oppose any of the Trustee's claims or requests for relief in the Mahwah Adversary

Proceeding, or any effort by the Trustee to obtain control of and/or sell the Mahwah Mansion. Critically, the settlement will ensure that any proceeds from an eventual sale of the Mahwah Mansion by the Trustee (if the Trustee prevails in the Mahwah Adversary Proceeding) are used first to pay the estate's expenses (including reasonable legal fees related to the Mahwah Adversary Proceeding) in connection with taking control of and selling the Mahwah Mansion, so that the estate will not be out of pocket even if future discussions between the Trustee and the Government regarding the distribution of sale proceeds of the Mahwah Mansion do not lead to a favorable settlement from the point of view of the estate.

C. Non-Working Travel (Task Code B195) Fees: \$11,852.75 Total Hours: 16.00

78. During the Fee Period, Paul Hastings attorneys traveled to the Federal Courthouse in Bridgeport, Connecticut, for August 14, 2023 and August 29, 2023 hearings in the Mahwah Adversary Proceeding. VII. Golden Spring Adversary Proceeding (Matter ID 00013)

A. General Litigation (Task Code B191) Fees: \$107,625.50 Total Hours: 95.30

79. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Golden Spring and China Golden Spring [Adv. Proc. No. 23-05018] (the "Golden Spring Adversary Proceeding"). In the Golden Spring Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Golden Spring is the alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Golden Spring and/or its assets (notwithstanding China Golden Spring's purported ownership interest in Golden Spring). During the Fee Period, Paul Hastings attorneys assisted the Trustee on all matters related to the Golden Spring Adversary Proceeding, including legal analysis of the claims

asserted against Golden Spring and China Golden Spring, preparing a motion to seal the complaint, and preparing a motion to set an answer deadline.

80. Golden Spring failed to respond to the complaint, and, on September 12, 2023,

the Trustee requested entry of a default judgment as against Golden Spring. The Court entered a

default judgment against Golden Spring by order dated September 20, 2023 [Docket No. 17 in

- A. Court Hearings (Task Code B155) Fees: \$43,234.50 Total Hours: 24.60 - 81. During the Fee Period, Paul Hastings attorneys attended numerous hearings

related to the HCHK Adversary Proceeding (as defined below), including:

- the July 11, 2023 and July 18, 2023 hearings on the Trustee's motion seeking approval of the Assignee Settlement (as defined below); - the August 8, 2023 status conference regarding the motion of the Proposed Intervenors (as defined below) seeking to intervene in the HCHK Adversary Proceeding; and - the August 15, 2023 pre-trial conference. - B. General Litigation (Task Code B191) Fees: \$596,122.00 Total Hours: 478.70 - 82. On June 8, 2023, the Trustee filed his complaint against the HCHK Entities, the

Assignee, Holy City Hong Kong Ventures, Ltd., Yvette Wang, and Anthony DiBattista [Adv.

Proc. No. 23-05013] (the "HCHK Adversary Proceeding"). In the HCHK Adversary

Proceeding, the Trustee seeks determinations that, among other things, (a) the HCHK Entities are

alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the

31 On October 11, 2023, the Trustee also requested entry of a default judgment against China Golden Spring, which also failed to respond to the complaint. As of the filing of this Application, the Court has not yet ruled on that request.

HCHK Entities and/or their assets. In addition, the complaint sought an injunction against the commencement or continuation of the assignment proceedings commenced with respect to the HCHK Entities in New York state court (the "Assignment Proceedings"). In connection with the HCHK Adversary Proceeding, the Trustee also requested and obtained a temporary restraining order (the "HCHK TRO") as it relates to the commencement or continuation of the Assignment Proceeding. See Docket No. 18 in Adv. Proc. No. 23-05013.

83. Shortly after the entry of the HCHK TRO, the Trustee successfully negotiated a settlement agreement (i.e., the Assignee Settlement) between the Trustee and the Assignee pursuant to Bankruptcy Rule 9019 and present such settlement to this Court. The Assignee Settlement provides for important benefits to the estate, including the deposit of over \$38 million of the HCHK Entities' funds into accounts controlled by the Trustee and the Assignee's commitment to not oppose the relief sought by the Trustee in the HCHK Litigation. During the Fee Period, Paul Hastings attorneys continued to assist the Trustee in prosecuting the Assignee Settlement, including preparing the Trustee's reply in further support of his motion for approval of the Assignee Settlement [Docket No. 45 in Adv. Proc. No. 23-05013]. The Assignee Settlement was approved by order dated July 28, 2023 [Docket No. 70 in Adv. Proc. No. 23- 05013]. In addition, after G-Club sought to prevent the turnover of portions of HCHK Technologies, Inc.'s ("HCHK Technologies") corporate documents under the Assignee Settlement, Paul Hastings attorneys prepared the Trustee's memorandum of law [Docket No. 86 in Adv. Proc. No. 23-05013] in support of the Trustee's argument that G-Club should not be permitted to prevent the turnover of such corporate records to the Trustee as part of the Assignee Settlement.

84. Furthermore, during the Fee Period, Paul Hastings attorneys continued to assist the Trustee on all matters related to the HCHK Adversary Proceeding. Most notably, Paul Hastings attorneys handled all matters related to the motion to intervene filed by Shin Hsin Yu, 1332156 B.C. LTD, GWGOPNZ Limited, Japan Himalaya League, Inc. (collectively, the "Proposed Intervenors") and their motion to clarify the HCHK TRO.32 For example, Paul Hastings attorneys prepared, among other things, the Trustee's motion to authorize and compel discovery from the Proposed Intervenors [Docket No. 67 in Adv. Proc. No. 23-05013] and the Trustee's objection to certain purported HCHK creditors to expedite the hearing on their motion to "clarify" the HCHK TRO. In addition, Paul Hastings attorneys handled the Trustee's discovery efforts with respect to the Proposed Intervenor's motion to intervene (including deposition preparation).

85. Finally, Paul Hastings attorneys also prepared (a) the Trustee's motion for an order setting a deadline for Holy City Hong Kong Ventures, Ltd. to respond to the Trustee's complaint [Docket No. 56 in Adv. Proc. No. 23-05013] and (b) the Trustee's objection to the motion filed by certain defendants seeking to extend the time to plead and the Trustee's related cross-motion to enter a default judgment against the defendants [Docket No. 110 in Adv. Proc. No. 23-05013]. On September 29, 2023, the Court entered a default judgment against Defendants HCHK Technologies, Inc., HCHK Property Management, Inc., Lexington Property and Staffing, Inc., and Holy City Hong Kong Ventures, Ltd. [Docket No. 139 in Adv. Proc. No. 23-05013].

32 The Trustee's substantive responses to these motions were filed on September 15, 2023 [Docket Nos. 118 and 119 in Adv. Proc. No. 23-05013], i.e., after the conclusion of the Fee Period. An evidentiary hearing on these motions has been scheduled for November 29, 2023.

C. Non-Working Travel (Task Code B195) Fees: \$7,953.75 Total Hours: 9.50

86. During the Fee Period, Paul Hastings attorneys traveled to the Federal Courthouse in Bridgeport, Connecticut, for July 11, 2023, July 18, 2023, and August 15, 2023 hearings in the HCHK Adversary Proceeding. IX. Interpleader Adversary (Matter ID 00015)

- A. General Litigation (Task Code B191) Fees: \$18,179.50 Total Hours: 11.30 - 87. On June 6, 2023, U.S. Bank commenced an interpleader action [Adv. Proc. No.

23-05012] (the "Interpleader Adversary Proceeding") to resolve a dispute regarding the release of the \$33 million in Escrow Funds held by U.S. Bank in escrow pursuant to an escrow agreement between HK USA, the Committee, and U.S. Bank (the "Escrow Agreement") entered into in connection with that certain *Stipulated Order Compelling HK International Funds Investments (USA) Limited, LLC to Transport and Deliver that Certain Yacht, The "Lady May"* entered by the Court on April 29, 2022 [Docket No. 299].33

88. While the bulk of the services provided to the Trustee in connection with the Interpleader Adversary Proceeding was undertaken by the Trustee's local counsel, i.e., NPM, Paul Hastings attorneys performed certain discrete tasks related to the Interpleader Adversary Proceeding, including analyzing and commenting on the draft reply in support of the Trustee's motion for summary judgment. Moreover, Paul Hastings attorneys handled the July 11, 2023 hearing on the Trustee's summary judgment motion.

33 U.S. Bank commenced the Interpleader Adversary Proceeding following the Court's ruling [Docket No. 221 in Adv. Proc. No. 22-05003] in the HK USA Adversary Proceeding that (a) among other things, all property of HK USA, including the Escrow Funds, are property of the Individual Debtor's estate, and (b) directing HK USA to deliver all property of HK USA to the Trustee. The Trustee takes the position that this ruling requires the immediate turnover of such funds to the Trustee. However, HK USA has refused to instruct U.S. Bank to release the funds to the Trustee and, instead, taken the position that, under the Escrow Agreement, the funds cannot be turned over to the Trustee, absent a final, non-appealable order to that effect.

89. On September 7, 2023, the Court granted the summary judgment motion [Docket No. 57 in Adv. Proc. No. 23-05012], authorizing the Trustee to remove the Escrow Funds from the segregated account and deposit such funds into the estate's general account(s).34

A. General Litigation (Task Code B191) Fees: \$96,447.00 Total Hours: 79.00

90. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against Mei Guo [Adv. Proc. No. 22-05008] (the "Mei Guo Adversary Proceeding"). In the Mei Guo Adversary Proceeding, the Trustee seeks (a) an order declaring that the proceeds, likely in an amount of over \$10 million, from the sale of the Individual Debtor's private Bombardier jet (the "Bombardier Proceeds") are property of the estate, (b) an order that Mei Guo surrender the Bombardier Proceeds or the value thereof to the Trustee because she received the Bombardier Proceeds as an unauthorized postpetition transfer avoidable under section 549 of the Bankruptcy Code, (c) an order that Mei Guo surrender to the Trustee the value of the Debtor's shell company Anton Development Limited at the time the company was transferred to her on June 27, 2017 (upon which date Anton Development Limited was title holder to the Bombardier jet) pursuant to a transaction avoidable as an actual fraudulent transfer, and (d) an order declaring that a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate.

91. During the Fee Period, Paul Hastings attorneys continued to handle the Mei Guo Adversary Proceeding, including (a) preparing initial disclosures, (b) preparing a joint pre-trial order, and (c) handling all discovery matters, including preparing discovery requests.

34 On September 14, 2023, HK USA appealed the summary judgment order [Docket No. 60 in Adv. Proc. No. 23- 05012].

A. General Litigation (Task Code B191) Fees: \$166,714.50 Total Hours: 122.60

92. During the Fee Period, Paul Hastings attorneys handled all matters arising out of HK USA and Mei Guo's appeal of this Court's rulings in connection with the Trustee's counterclaims against HK USA and Mei Guo [Adv. Proc. No. 22-05003] (the "HK USA Adversary Proceeding"). In the HK USA Adversary Proceeding, this Court determined that, among other things, (a) the Lady May and the Lady May II are property of the Individual Debtor's estate, (b) HK USA is an alter ego of the Individual Debtor, and (c) the \$33 million held in escrow by U.S. Bank are property of the estate [Docket Nos. 172 and 221 in Adv. Proc. No. 22-05003].

93. HK USA and Mei Guo have appealed these ruling to the District Court as well as sought a stay pending appeal. In connection with this appeal, Paul Hastings attorneys prepared, among other things, (a) the Trustee's response to the appellants' emergency motion for a stay pending appeal (which motion to the District Court denied), and (b) the Trustee's appellee brief (which was filed on September 6, 2023). XII. Bravo Luck Adversary (Matter ID 00018)

A. General Litigation (Task Code B191) Fees: \$ \$75,247.50 Total Hours: 50.80

94. During the Fee Period, Paul Hastings attorneys assisted the Trustee, Genever (BVI), and Genever (US) in negotiating a consensual resolution of their claims against Bravo Luck and the Debtors' son, Mr. Qiang Guo [Adv. Proc. No. Adversary Proceeding No. 23- 05027] (the "Bravo Luck Adversary Proceeding"). In the Bravo Luck Adversary Proceeding, the Trustee, Genever (BVI), and Genever (US) had challenged the validity and enforceability of a

purported trust agreement between the Individual Debtor, Genever (BVI), Genever (US), and Bravo Luck, pursuant to which Bravo Luck was purportedly granted a beneficial ownership of the Sherry Netherland Apartment, as well as asserting fraudulent transfer claims against Bravo Luck and Mr. Qiang Guo.

95. In particular, during the Fee Period, Paul Hastings attorneys negotiated and prepared the settlement agreement with Bravo Luck and Mr. Qiang Guo as well as prepared the related motion to approve such settlement, which motion was filed on August 4, 2023 [Docket No. 111 in Adv. Proc. No. 23-05027]. As a result of the settlement, the Trustee, Genever (US) and Genever (BVI) obtained the primary relief they sought in the Bravo Luck Adversary Proceedings—namely, undisputed beneficial ownership and control of the Sherry Netherland Apartment. The settlement was approved by order dated August 30, 2023 [Docket No. 118 in Adv. Proc. No. 23-05027]. To the extent not obvious from the settlement documents filed in connection with this motion, the settlement reflects a complete and unconditional vindication of the Trustee's position in this matter. XIII. Greenwich Land Adversary (Matter ID 00020)

A. General Litigation (Task Code B191) Fees: \$735,135.50 Total Hours: 586.80

96. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against Greenwich Land and Hing Chi Ngok [Adv. Proc. No. 23-05005] (the "Greenwich Land Adversary Proceeding"). In the Greenwich Land Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Greenwich Land is an alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Greenwich Land. Paul Hastings' efforts thus far have resulted in critical prejudgment remedies and injunctive relief to protect the assets of Greenwich Land, including the Individual Debtor's mansion on Taconic

Road in Greenwich, Connecticut, pending the outcome of the Greenwich Land Adversary Proceeding, for the benefit of the estate.

97. During the Fee Period, Paul Hastings attorneys prepared several filings in the Greenwich Land Adversary Proceeding, including, most notably, the Trustee's objection to defendants' motion to withdraw the reference to the District Court [Docket No. 63 in Adv. Proc. No. 23-05005]. All the while, Paul Hastings handled all matters related to the discovery in the Greenwich Land Adversary Proceeding, including (a) preparing responses to the defendants' document requests, interrogatories, and requests for admission, (b) preparing subpoenas and deposition notices, (c) reviewing documents produced, (d) participating in meet & confer sessions with the defendants, (e) preparing for depositions, and (f) preparing witness declarations. In addition, Paul Hastings attorneys deposed Ms. Emile DeNeree (the former real estate broker to the Individual Debtor) on August 24, 2023, and defended the deposition of the Trustee on August 23, 2023. All these discovery efforts culminated in the Trustee's motion for summary judgment [Docket No. 77 in Adv. Proc. No. 23-05005], which was filed on October 10, 2023. Among other things, the Trustee submits that summary judgment is appropriate here because the defendants have no knowledge of the management or operations of Greenwich Land, nor do they have any basis to dispute the substantial evidence that the Debtor is, and always has been, the one who truly owns and controls Greenwich Land.

98. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code provides that, after notice and a hearing, the Court may award a professional employed under 11

U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).35

99. In determining the amount of "reasonable compensation," the Court must consider the nature, extent, and value of the services, taking into account all the relevant factors, including the time spent on such services, the rates charged for such services, whether the services were necessary and beneficial, whether the services were performed in a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communication Systems, Inc., 395 B.R. 512 (D. Conn. 2008).

100. In assessing the "reasonableness" of the fees requested, the Second Circuit has stated that courts should consider the factors enumerated in Johnson v. Ga. Highway Express, Inc., 36 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections, 522 F.3d 182, 190 (2d Cir. 2007) (citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir.1974), abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87, 92–93, 96 (1989)). The

35 Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code "on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis." 11 U.S.C. § 328(a).

36 The twelve Johnson factors are (1) the time and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service properly, (4) the preclusion of other employment by the attorney due to acceptance of the case, (5) the customary fee, (6) whether the fee is fixed or contingent, (7) the time limitations imposed by the client or the circumstances, (8) the amount involved and the results obtained, (9) the experience, reputation, and ability of the attorneys, (10) the "undesirability" of the case, (11) the nature and length of the professional relationship with the client, and (12) awards in similar cases. Johnson, 488 F.2d at 717-19.

"lodestar method" of calculating the reasonable fee contemplates "the number of hours

reasonably expended . . . multiplied by a reasonable hourly rate." See Hensley v. Eckerhart, 461

U.S. 424, 433 (1983); Gisbrecht v. Barnhart, 535 U.S. 789, 801 (2002); Perdue v. Kenny A., 130

S.Ct. 1662, 1672 (2010); In re Drexel Burnham Lambert Grp., Inc., 133 B.R. 13 (Bankr.

S.D.N.Y. 1991). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544

F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.37 See In re Nine Assocs.,

Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine

Magazine, Inc., 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); Green v. City of New York,

403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); see generally 3 COLLIER ON

BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing First Colonial

and Johnson as the "leading cases with regard to the factors to be considered in determining a

reasonable allowance of compensation").

101. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Paul Hastings is fair and reasonable, as set forth below and otherwise in this Application.

Paul Hastings billed a total of \$3,725,984.25 and 3031.60 hours, respectively, of professional and paraprofessional services during the Fee Period. As evidenced by this Application, Paul Hastings professionals and paraprofessionals worked diligently and efficiently without unnecessary duplication of efforts throughout the Fee Period. A small group of the same Paul Hastings attorneys was utilized for the vast majority of the work in order to minimize the costs of intra-Paul Hastings communication and education about the Debtors' circumstances. Whenever possible, Paul Hastings sought to minimize the cost of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. The services were performed in an effective and efficient manner commensurate with the complexity, exigency, and

37 The factors articulated in First Colonial were first articulated by the Fifth Circuit in Johnson, with the First Colonial court adding the factor of the "spirit of economy," which was later rejected by Congress. See Stroock & Stroock & Lavan v. Hillsborough Holdings Corp. (In re Hillsborough Holdings Corp.), 127 F.3d 1398, 1403 (11th Cir. 1997).

importance of the issues involved. In addition, Paul Hastings' representation has required it to balance the need to provide quality services with the need to act quickly and represent the Trustee and the Genever Debtors in an effective, efficient, and timely manner. Paul Hastings submits that the hours spent were reasonable given the size and complexity of these chapter 11 cases, the significant, and often urgent, legal and business issues raised, and the numerous pleadings filed in the chapter 11 cases. Furthermore, as noted detailed above, the Trustee and the Genever Debtors also retained NPM as local and conflicts counsel in order to provide services to the Trustee and the Genever Debtors in a costeffective manner. Paul Hastings and NPM have coordinated and will continue to coordinate each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. b. Novelty and Difficulty of the Questions

Paul Hastings tasked knowledgeable attorneys to research, analyze, and advise the Trustee and the Genever Debtors on difficult and complex issues during the Fee Period, including issues related to bankruptcy and litigation. Most notably, as detailed in this Application, Paul Hastings investigated complex estate claims and causes of action in order to recover assets of these estates. c. Skill Requisite to Perform the Legal Services Properly

Paul Hastings believes that its recognized expertise in the areas of financial restructuring and corporate reorganization, its ability to draw from highly experienced professionals in other areas of Paul Hastings' practice, and its creative approach to the resolution of issues has contributed to the effective administration of these chapter 11 cases and benefited the Trustee, the Genever Debtors, their estates, and their unsecured creditors. Due to the nature and complexity of the legal issues presented by these chapter 11 cases, Paul Hastings was required to exhibit a high degree of legal skill in areas related to, among others, bankruptcy and litigation. d. Preclusion of Other Employment by Applicant Due to Acceptance of the Case

Due to the size of Paul Hastings' restructuring and litigation departments, Paul Hastings' representation of the Trustee and the Genever Debtors did not preclude its acceptance of new clients, but the demands for immediate and substantive action in these chapter 11 cases imposed significant burdens on Paul Hastings professionals and paraprofessionals working concurrently on other matters. That said, for the Trustee, his engagement as a chapter 11 trustee has, for all practical purposes precluded other employment given that this matter is taking up most of his time and there frequently are two hearings per week.

The fees charged by Paul Hastings in these chapter 11 cases are billed in accordance with its existing billing rates and procedures in effect during the Fee Period. The rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to

the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. Moreover, when Paul Hastings' restructuring professionals and paraprofessionals work on nonbankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable nonbankruptcy cases in a competitive national legal market. In addition, the firm's customary hourly rates and rate structure reflect that restructuring and related matters typically involve great complexity, numerous tasks requiring a high level of expertise, and severe time pressures, as is the case here. f. Whether the Fee Is Fixed or Contingent

Pursuant to Bankruptcy Code sections 330 and 331, all fees sought by professionals employed under Bankruptcy Code section 1103 are subject to final approval by the Court, and are subject to adjustment depending on the services rendered and the results obtained. Of particular note, payment of Paul Hastings' fees here was contingent in two respects: (1) the recovery of assets for the benefit of the estates and (2) monetizing such assets. At the outset of these chapter 11 cases, there was no assurance whatsoever that assets would be recovered and monetized to allow for the payment of estate professionals. Accordingly, Paul Hastings' compensation was, in essence, a contingency fee arrangement. The risk that Paul Hastings assumed by representing the Trustee and the Genever Debtors further supports the reasonableness of Paul Hastings' compensation. g. Time Limitations Imposed by the Client or Other Circumstances

During the Fee Period, Paul Hastings was required to analyze and address certain issues arising in these chapter 11 cases under compressed timelines. For example, given the Individual Debtor's track record of moving assets to keep them out of reach of creditors, it was critical that Paul Hastings act quickly on information obtained during the Trustee's investigation in order to freeze assets.

Paul Hastings professionals and paraprofessionals worked diligently to maximize value for these chapter 11 estates. During the Fee Period, and as described in the summary of services herein, Paul Hastings was instrumental in analyzing potential sources of recovery for the benefit of these estates. As a result of Paul Hastings' efforts, the Trustee has been able to recover, among other assets, the Lady May, the Lady May II, and \$33 million in escrow funds. Moreover, on August 1, 2023, the Trustee received approximately \$38.8 million in funds pursuant to the settlement with the Assignee in the HCHK Adversary Proceeding. Furthermore, during the Fee Period, Paul Hastings was able to secure several key rulings from the Court, which rulings will serve as a beachhead for future asset recovery efforts. The reasonableness of Paul Hastings' fees must be evaluated in light of this important strategic factor as well. i. Experience, Reputation, and Ability of Attorneys

Paul Hastings is consistently recognized as a top tier law firm in the field of business reorganizations and liquidations under chapter 11. During the Application Period, Paul Hastings solicited the skill and expertise of its professionals and paraprofessionals. Paul Hastings professionals have actively represented debtors, creditors, and creditors' committees, as well as other parties in interest, in a number of the nation's largest chapter 11 cases as well as in connection with cross-border restructurings. Paul Hastings' extensive experience enables it to perform the services described herein competently and expeditiously. In addition to its expertise in the area of corporate reorganization, Paul Hastings has called upon the expertise of its attorneys in other practice areas as required during the Fee Period.

As detailed in this Application, the Individual Debtor's in-court and out-of-court tactics illustrate the undesirability of this engagement, which involved harassment of the Trustee and Paul Hastings attorneys (including death threats against the Trustee). As a result, Paul Hastings was forced to incur hundreds of thousands of dollars in cyber security measures (the cost of which are not part of the expenses for which Paul Hastings is seeking reimbursement in this Application). In addition, prior to the Court granting the First Interim Fee Application at the end of June 2023, Paul Hastings was unable to get paid for its fees for almost a year. k. Nature and Length of Professional Relationship

Paul Hastings has been rendering professional services to (a) the Trustee since its retention as counsel effective as of July 8, 2022, (b) Genever (BVI) since its retention as counsel effective as of October 11, 2022, and (c) Genever (US) since its retention as counsel effective as of November 3, 2022.

102. Paul Hastings respectfully submits that the services for which it seeks

compensation in this Fee Application were, at the time rendered, necessary for and beneficial to the Debtors' estates and their creditors and were rendered to maximize, protect, and preserve value for the Debtors' estates and all parties in interest. Paul Hastings believes that it provided services economically, effectively, and efficiently, and obtained results beneficial to the Debtor's estate and his creditors. Paul Hastings further submit that the compensation requested herein is reasonable in light of the nature, extent, and value of the services rendered during the Fee Period.

103. Paul Hastings also notes that the rates charged during the Fee Period are

reasonable. In fact, this Court recently held that Paul Hastings' New York rates are reasonable

because Paul Hastings was retained at New York rates and these cases are extraordinary within this District. See Order Denying Motion for Stay Pending Appeal [Docket No. 1791].

104. All fees incurred by Paul Hastings during the Fee Period were actual, reasonable, and necessary in the performance of services for the Trustee and the Genever Debtors. Paul Hastings respectfully requests approval of the compensation sought herein.

105. As set forth in Exhibit C hereto, Paul Hastings incurred and disbursed \$146,137.57 as expenses in providing professional services during the Fee Period. These expenses include approximately \$15,562.56 for online legal research (i.e., LEXIS and Westlaw). Because Paul Hastings believes that online legal research (e.g., LEXIS and Westlaw) is far more cost-efficient than manual research using hard-bound volumes, Paul Hastings encourages computerized legal research even though it is not a profit center for Paul Hastings. To be clear, Paul Hastings does not charge a mark-up on the LEXIS and Westlaw charges, but merely passes on the costs of such third-party services. Moreover, as it relates to outside professional services, mailing, and other service-related expenses, the Trustee and Paul Hastings are merely passing on the costs of such third-party services, without any mark-up.38

106. Additional necessary expenses included:

- \$94,724.02 for certain outside professional services, such as document review services by UnitedLex (\$93,448.02) and translation services by Divergent Language Solutions (\$1,276.00); - \$5,735.52 for document reproductions, namely \$5,312.32 for b/w reproductions (at 8 cents per page) and \$423.20 for color reproductions (at 20 cents per page); - \$5,256.99 for UPS/courier service, including service of pleadings required to be served in hard copy format;

38 Documentation of these expenses will be made available to the Court upon request.

- \$3,576.19 for court reporting services; - \$1,725.00 for process servers (e.g., Metro Attorney Service Inc.) to serve, among other things, the subpoenas issued pursuant to the Rule 2004 orders entered by this Court; and - \$321.35 for corporate document retrieval services (including United Corporate Service and Corp2000) with respect to various Kwok-related entities.

107. During the Fee Period, Paul Hastings utilized UnitedLex—a third party vendor that specializes in discovery services including document processing, storage, review services, and distribution—to conduct document review of the documents produced in the chapter 11 cases, including the more than 140,000 discovery documents received by the Trustee to date in connection with his investigation.

108. Using their own contract attorneys and review team managers, UnitedLex provides an efficient and economic means of reviewing large document sets at hourly rates significantly lower than Paul Hastings. UnitedLex's document review team charges hourly rates ranging from \$40 to \$55 (for non-management roles) and \$150 (for management role), which is substantially less than Paul Hastings' hourly rates and, moreover, is even less than the hourly rates of associates of local Connecticut counsel (i.e., NPM), which rates range from \$200 to \$400. For all these reasons, Paul Hastings believes that utilizing the UnitedLex document review team greatly benefits these estates by reducing document review costs. The Trustee also previewed Paul Hastings' use of UnitedLex with the U.S. Trustee, who had no objection thereto (without the Trustee having to file a separate retention application for UnitedLex). The Trustee and Paul Hastings also disclosed in the Fourth Supplemental Declaration of Disinterestedness of Luc A. Despins [Docket No. 1435] that Paul Hastings would utilize UnitedLex's contract attorneys services.

109. The time constraints imposed by the circumstances of the matters handled by Paul Hastings during the Fee Period required its attorneys and other employees, at times, to devote substantial time during the evenings and on weekends to perform legal services on behalf of the Trustee. These extraordinary services were essential to meet deadlines, timely respond to inquiries on a daily basis, and satisfy the Trustee's needs and demands. Attorneys and other Paul Hastings employees who worked late in the evenings or on weekends were reimbursed for their reasonable meal and transportation costs in accordance with firm policy. Paul Hastings' regular practice is not to include components for those charges in overhead when establishing billing rates, but rather to charge its clients for these and all other out-of-pocket disbursements incurred during the regular course of the provision of legal services.

110. In accordance with Appendix D (Guidelines for Compensation and Expense Reimbursement of Professionals) to the Local Rules, reproduction charges have been capped at 20 cents per page. 39

111. The expenses requested herein are customarily charged to non-bankruptcy clients of Paul Hastings. Additionally, the expenses incurred by Paul Hastings to third parties are limited to the actual amounts billed to, or paid by, Paul Hastings on behalf of the estates.

112. Paul Hastings believes the rates for charges incurred are the market rates that the majority of law firms charge clients for such services. In addition, Paul Hastings believes that such charges are in accordance with the American Bar Association's ("ABA") guidelines, as set forth in the ABA's Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other charges.

39 Generally, Paul Hastings charges 8 cents per page for black-and-white reproductions and 50 cents per page for color reproductions. In accordance with Appendix D to the Local Rules, Paul Hastings has reduced the charge for color reproductions to 20 cents per page.

113. The expenses incurred in providing professional services in the Chapter 11 Case

were necessary, economical, and justified under the circumstances.

114. Paul Hastings responds to the questions set forth in Paragraph C.5. of the U.S.

Trustee Guidelines as follows:

Question: Did you agree to any variations from, or alternatives to, your standard or customary billing rates, fees, or terms for services pertaining to this engagement that were provided during the Fee Period?

Response: Yes. As a courtesy to these estates and based on circumstances unique to these chapter 11 cases, during the Fee Period, Paul Hastings agreed to voluntary fee reductions

\$124,820.25, including the following:

Paul Hastings did not implement the August 1, 2023 firm wide hourly rate increase in these chapter 11 cases and, instead, maintained the existing rates for the Fee Period.

in waived fees.

Paul Hastings is not seeking allowance or payment at this

Period. The total amount of such fees is \$37,232.00. The time

Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

result of the agreed-upon reduction in Luc Despins' hourly rate (from his standard hourly rate of \$1,975 to the reduced hourly rate of \$1,860), an additional \$25,351.75

Question: If the fees sought in this application as compared to the fees

discuss the reasons for the variation with the client. Response: Not applicable.

Question: Have any of the professionals included in this application varied their hourly rate based on the geographic location of the bankruptcy case?

Response: No.

Question: Does the application include time or fees related to reviewing or revising time records or preparing, reviewing, or revising invoices? (This is limited to work involved in preparing and editing billing records that would not be compensable outside of bankruptcy and does not include reasonable fees for preparing a fee application.) If so, please quantify by hours and fees.

Response: The Application does not include time for preparing, reviewing, or revising time records. However, the Application does include approximately 36.5 hours and associated fees of approximately \$58,916.00 related to preparing, reviewing, and revising Paul Hastings' fee statements and ensuring time entries are properly categorized by matter number and task code. On average, less than 7.5 hours were spent on each of the five monthly fee statements prepared during the Fee Period.

- Question: Does this application include time or fees for reviewing time records to redact any privileged or other confidential information? If so, please quantify by hours and fees. - Response: No.

Question: If the application includes any rate increases since retention: (i) Did your client review and approve those rate increases in advance? (ii) Did your client agree when retaining the law firm to accept all future rates increases? If not, did you inform your client that they need not agree to modified rates or terms in order to have you continue the representation consistent with ABA Formal Ethics Opinion 11-458?

Response: As is customary, Paul Hastings adjusts its hourly rates periodically based upon (i) the advancing seniority of its professionals and paraprofessionals, (ii) the current market for legal services, (iii) the rates charged for comparable non‐bankruptcy services, and (iv) the firm's analysis of the hourly rates being charged by professionals in other law firms. Effective January 1, 2023, Paul Hastings adjusted its hourly rates consistent with the Retention Order [Docket No. 668] and the Notice of Change in Hourly Rates of Paul Hastings LLP, Counsel to Chapter 11 Trustee [Docket No. 1251].

115. To the extent that time or disbursement charges for services rendered or expenses incurred during the Fee Period are not included in this Application, or the Trustee and Paul Hastings have for any reason not sought compensation or reimbursement with respect to such services, Paul Hastings reserves the right to request compensation and reimbursement for such services in a supplemental or future application in the Debtors' chapter 11 cases. Also, Paul Hastings does not waive, and expressly reserves, its right to respond to any objections regarding this Application and the amounts sought for services rendered and expenses incurred.

116. No previous request for the relief sought herein has been made to this Court or any other court.

[Remainder of page intentionally left blank.] Case 22-50073r-Ddd 2256 Filed 10/16/23-1Entered 10/16/23 22:05:06 94Page 259 of

WHEREFORE, Paul Hastings respectfully requests entry of an order, substantially in the form attached hereto as Exhibit G, (i) allowing interim compensation for professional services rendered during the Fee Period in the amount of \$3,725,984.25 and reimbursement of \$146,137.57 in expenses, (ii) authorizing payment from the Debtors' estates of 80% of such compensation and 100% of such expenses as it relates to the July 2023 and August 2023 services, (iii) allowing such compensation and payment for professional services rendered and reimbursement of actual and necessary expenses incurred without prejudice to the Trustee's and Paul Hastings' right to seek further compensation and/or payment from the Debtors' estates for the full value of services performed and expenses incurred, and (iv) granting the Trustee and Paul Hastings such other and further relief as is just.

Dated: October 16, 2023 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

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

Avram E. Luft (admitted pro hac vice) G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com alexbongartz@paulhastings.com

Counsel for the Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC

Customary and Comparable Compensation Disclosures

The blended hourly rate for Paul Hastings' timekeepers in its New York office who billed to non-bankruptcy matters (collectively, the "Non-Bankruptcy Matters")1 during the twelve-month period beginning on September 1, 2022 and ending on August 31, 2023 was, in the aggregate, approximately \$1,150 per hour. The blended hourly rate for Paul Hastings' timekeepers who billed to the Debtor's chapter 11 cases during the Fee Period was approximately \$1,229 per hour. A detailed comparison of these rates follows:

Category of Timekeeper Blended Hourly Rate

Blended Hourly Rate Debtor Blended Hourly

All Timekeepers Aggregated \$1,150 \$1,229

1 It is the nature of Paul Hastings' practice that certain non-bankruptcy engagements require the advice and counsel of professionals and paraprofessionals who work primarily within Paul Hastings' restructuring group. Accordingly, Non-Bankruptcy Matters consist of matters for which Paul Hastings' timekeepers represented a client in matters other than court-approved engagements as counsel for the debtor, the chapter 11 trustee, or an official committee under the Bankruptcy Code. As such, the Non-Bankruptcy Matters include, in part, time billed by Paul Hastings' timekeepers who work primarily within Paul Hastings' restructuring group.

2 Luc A. Despins, the lead attorney on this matter and the co-chair of Paul Hastings' Global Restructuring Practice, brings to the Title III Cases over 35 years of experience representing debtors and creditors in high profile and complex restructuring matters. Given the complexity and challenges faced by the Trustee in these cases, a significant amount of time by senior partners, of counsel, and senior associates, including Mr. Despins, Nicholas Bassett, Alexander Bongartz, Avi Luft, Douglass Barron, and Shlomo Maza has been necessary. Because their rates are at the higher end of the range of rates billed by Paul Hastings partners, of counsel, and associates, respectively, and in light of the fact that a significant amount of senior partner, of counsel, and senior associate time has been required for this engagement, the blended rate for this case moved to the higher end of the range of rates billed by Paul Hastings. Finally, the blended attorney hourly rate for the Fee Period is not comparable to the average hourly rate in other matters because it does not reflect numerous cost-saving measures, including the delegation of a variety of matters to NPM, matters for which otherwise more junior Paul Hastings attorneys with lower hourly rates would have been used, thereby reducing Paul Hastings' blended hourly rate.

Summary of Timekeepers Included in this Application

Bassett, Nicholas Corporate, 2007 \$1,625.00 261.10 \$424,287.50 1 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$812.50 8.50 \$6,906.25 1 Cota, Alex Corporate, 2012 \$1,725.00 7.20 \$12,420.00 N/A Despins, Luc Restructuring, 1986 \$1,860.00 218.30 \$406,038.00 N/A Despins, Luc (travel; ½ rate) Restructuring, 1986 \$930.00 4.30 \$3,999.00 N/A

Bongartz, Alex Restructuring, 2007 \$1,625.00 172.00 \$279,500.00 1 Bongartz, Alex (travel; ½ rate) Restructuring, 2007 \$812.50 1.30 \$1,056.25 1 Luft, Avi Corporate, 2000 \$1,625.00 385.20 \$625,950.00 1 Luft, Avi (travel; ½ rate) Corporate, 2000 \$812.50 18.90 \$15,356.25 1 Traxler, Katherine Restructuring, 1990 \$1,025.00 7.40 \$7,585.00 1

Barron, Douglass Corporate, 2012 \$1,320.00 314.50 \$415,140.00 1 Catalano, Kristin Corporate, 2021 \$915.00 107.50 \$98,362.50 1 Farmer, Will Corporate, 2018 \$1,235.00 235.20 \$290,472.00 1 Ganapathi, Anuva Litigation, 2021 \$915.00 11.60 \$10,614.00 1 Grabias, Maria Corporate, 2016 \$1,290.00 16.30 \$21,027.00 N/A Kim, Sarah Litigation, 2023 \$855.00 9.10 \$7,780.50 N/A Koch, Leonie Corporate, 2023 \$855.00 9.20 \$7,866.00 1 Kosciewicz, Jon Litigation, 2021 \$915.00 102.10 \$93,421.50 1 Maza, Shlomo Corporate, 2012 \$1,320.00 152.50 \$201,300.00 1 Sadler, Tess Corporate, 2019 \$1,175.00 14.40 \$16,920.00 1 [redacted] Corporate, 2023 \$815.00 353.90 \$288,428.50 1 [redacted](travel ½ rate) Corporate, 2023 \$407.50 7.00 \$2,852.50 1 Sutton, Ezra Corporate, 2021 \$1,015.00 307.50 \$312,112.50 1 [redacted] Corporate, 2022 \$915.00 29.40 \$26,901.00 Associate Total: 1,670.20 \$1,793,198.00

Kuo, Jocelyn Paralegal \$540.00 92.80 \$50,112.00 N/A Mohamed, David Paralegal \$540.00 184.40 \$99,576.00 1 Paraprofessional Total: 277.20 \$149,688.00

Weitzman, Avi Litigation, 2000 \$1,700.00 2.10 \$3,570.00

Shelley, Scott Corporate, 1994 \$1,525.00 4.10 \$6,252.50 Strickon, Harvey Corporate, 1972 \$1,900.00 0.30 \$570.00 Zhu, Sarah Litigation, 2017 \$1,500.00 0.20 \$300.00

Daly, Crispin Corporate, 2010 \$1,320.00 1.60 \$2,112.00 Hibbard, Jack Corporate, 2022 \$855.00 4.70 \$4,018.50 Miliotes, Lanie Corporate, 2023 \$855.00 4.30 \$3,676.50 Shum, Kevin Corporate, 2014 \$1,235.00 1.60 \$1,976.00 [redacted] Corporate, 2016 \$1,125.00 2.40 \$2,700.00

Langer, Bobbi Real Estate, 1984 \$975.00 2.40 \$2,340.00 Swartz, Robin Real Estate, 1992 \$1,255.00 1.00 \$1,255.00

Austin, Javii Legal Research Analyst \$400.00 3.80 \$1,520.00 Chang, Irene Legal Research Analyst \$400.00 0.60 \$240.00 Ecklund, Amy Technical Operations Senior

Elliott, Elizabeth Legal Research Analyst \$400.00 2.60 \$1,040.00 Funao, Miho Administrative Professional \$250.00 0.30 \$75.00 Hopkovitz, Yael Legal Research Attorney \$450.00 1.60 \$720.00 Liu, Kelly Legal Research Analyst \$400.00 3.40 \$1,360.00 Lopez, Mayra Technical Operations Senior

O'Dea, Heather Legal Research Analyst \$400.00 2.50 \$1,000.00 Reid, Alex Legal Research Analyst \$400.00 1.80 \$720.00 Paraprofessional Total: 21.10 \$8,461.50

Summary of Timekeepers Not Included in this Application1

1 As noted, as an accommodation to these estates, Paul Hastings is not seeking allowance or payment at this time for the fees of timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$37,232.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

Summary of Compensation by Project Category

U.S. Trustee Task Code and Project Category Hours

B110 Case Administration 82.20 \$75,463.50 B113 Pleadings Review 86.50 \$48,015.50 B120 Asset Analysis and Recovery 1.10 \$2,046.00 B130 Asset Disposition 8.50 \$11,226.50 B131 Sale of Real Estate 8.20 \$10,621.00 B155 Court Hearings 120.20 \$151,382.50 B160 Employment / Fee Applications (Paul Hastings) 103.60 \$148,148.50 B165 Employment / Fee Applications (Other Professionals) 48.00 \$74,470.00 B190 Other Contested Matters 59.60 \$77,833.50 B191 General Litigation 1,796.60 \$2,252,200.00 B195 Non-Working Travel 40.00 \$30,170.25 B210 Business Operations 36.40 \$55,663.00 B211 Financial Reports (Monthly Operating Reports) 9.30 \$10,983.00 B230 Financing / Cash Collections 174.00 \$225,833.00 B261 Investigations 451.20 \$542,812.50 B262 Contempt Proceedings 5.10 \$7,897.50 B310 Claims Administration and Objections 1.10 \$1,218.00

Matter ID Matter Name July 2023 August 2023 Total Fees

Representation \$362,796.50 \$232,991.50 \$595,788.00

and Litigation \$219,121.50 \$423,272.75 \$642,394.25 00003 Other Litigation \$2,431.00 \$50,735.00 \$53,166.00 00004 Corporate Law Issues \$12,843.50 \$12,843.50 00005 Sale Process \$7,875.50 \$2,275.00 \$10,150.50 00006 Tax Issues \$0.00 \$0.00 \$0.00 00007 Foreign Law Issues \$0.00 \$0.00 \$0.00 00008 Plan Process Issues \$0.00 \$0.00 \$0.00 00010 Genever US \$33,189.75 \$102,545.50 \$135,735.25 00011 Genever BVI \$0.00 \$2,386.50 \$2,386.50 00012 Mahwah Adversary \$98,916.00 \$313,918.75 \$412,834.75 00013 Golden Spring Adversary \$90,231.50 \$17,394.00 \$107,625.50 00014 HCHK Adversary \$355,217.75 \$292,092.50 \$647,310.25 00015 Interpleader Adversary \$24,050.00 \$792.00 \$24,842.00 00016 Mei Guo Adversary \$42,793.50 \$53,653.50 \$96,447.00 00017 HK USA Adversary \$76,657.00 \$95,988.75 \$172,645.75 00018 Bravo Luck Adversary \$68,595.50 \$6,652.00 \$75,247.50 00019 SN Apartment Adversary \$1,300.00 \$132.00 \$1,432.00 00020 Greenwich Land Adversary \$323,941.00 \$411,194.50 \$735,135.50 00022 PAX Adversary \$0.00 \$0.00 \$0.00 TOTAL \$1,719,960.00 \$2,006,024.25 \$3,725,984.25

Expense Category July 2023 August 2023 Total Expenses

Airfare (Nicholas Bassett) \$2,192.51 \$1,127.81 \$3,320.32 Articles and Publications \$28.35 \$0.00 \$28.35 Attorney Service (Service of Documents): - Metro Attorney Service \$575.00 \$1,150.00 \$1,725.00 Computer Search (Other) \$769.68 \$944.82 \$1,714.50 Court Reporting Services (Transcripts) \$0.00 \$3,576.19 \$3,576.19

Lexis/On Line Search \$2,007.60 \$3,139.98 \$5,147.58 Local - Meals \$417.03 \$63.93 \$480.96 Local - Parking \$19.00 \$0.00 \$19.00

Outside Professional Services: - Divergent Language Solutions \$0.00 \$1,276.00 \$1,276.00 - Bohonnon Law Firm, LLC \$3,831.75 \$0.00 \$3,831.75 - UnitedLex \$93,448.02 \$0.00 \$93,448.02

Postage/Express Mail \$540.22 \$1,641.91 \$2,182.13 Reproduction Charges \$2,075.52 \$3,236.80 \$5,312.32 Reproduction Charges (Color) \$272.00 \$151.20 \$423.20 Retrieval of Corporate Documents: - TransUnion Risk \$220.00 \$11.25 \$231.25

Search Fees \$1,172.84 \$0.00 \$1,172.84 Taxi/Ground Transportation \$1,538.02 \$652.37 \$2,190.39 Travel Expense - Internet \$30.00 \$0.00 \$30.00 Travel Expense - Meals \$119.17 \$54.10 \$173.27 Travel Expense - Parking \$172.99 \$43.00 \$215.99 UPS/Courier Service \$849.98 \$4,407.01 \$5,256.99 Vendor Expense \$93.00 \$158.87 \$251.87 Westlaw \$4,799.44 \$3,896.84 \$8,696.28

TOTAL \$120,605.49 \$25,532.08 \$146,137.57

*PAUL HASTINGS LLP 1117 S California Avenue, Palo Alto, CA 94304-1106 t: +1 650 320 1800 f: +1 650 320 1900 www paulhastings com*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan September 7, 2023 Kwok 200 Park Avenue New York, NY 10166 Please Refer to Invoice Number: 2369632

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$362,796.50

Total Balance Due - Due Upon Receipt \$367,660.06

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

*PAUL HASTINGS LLP 1117 S California Avenue, Palo Alto, CA 94304-1106 t: +1 650 320 1800 f: +1 650 320 1900 www paulhastings com*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan September 7, 2023 Kwok 200 Park Avenue New York, NY 10166 Please Refer to Invoice Number: 2369632

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$362,796.50

Total Balance Due - Due Upon Receipt \$367,660.06

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

*PAUL HASTINGS LLP 1117 S California Avenue, Palo Alto, CA 94304-1106 t: +1 650 320 1800 f: +1 650 320 1900 www paulhastings com*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan September 7, 2023

New York, NY 10166 Invoice Number: 2369632

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2023 General Chapter 11 Trustee Representation \$362,796.50

Date Initials Description Hours Rate Amount

07/03/2023 DM26 Update critical dates calendar and send outlook reminders (.5); review and update

07/05/2023 DM26 Update critical dates calendar and send outlook reminders (.5); prepare list of filing

filing deadlines (.2) 1.10 540.00 594.00 07/05/2023 ECS1 Update case issues/task list 1.40 1,015.00 1,421.00 07/05/2023 ECS1 Update trackers regarding upcoming deadlines and critical dates and share with

07/05/2023 JK21 Prepare statement of withdrawal of counsel for electronic filing (0.3); electronically file with the court statement of withdrawal of

Date Initials Description Hours Rate Amount 07/06/2023 DM26 Update critical dates calendar and send outlook reminders (.6); review and update

07/06/2023 ECS1 Update case trackers regarding critical dates

07/07/2023 DM26 Update critical dates calendar and send

07/10/2023 AB21 Update list of open issues and workstreams 0.20 1,625.00 325.00 07/10/2023 DM26 Update critical dates calendar and send

07/11/2023 DM26 Update critical dates calendar and send

07/11/2023 LAD4 T/c S. Sarnoff (OMM) re: update on case 0.40 1,860.00 744.00 07/12/2023 DM26 Update critical dates calendar and send

07/13/2023 AB21 Correspond with E. Sutton regarding updates to issues/task list 0.10 1,625.00 162.50 07/13/2023 DM26 Update critical dates calendar and send

07/13/2023 ECS1 Prepare issues/task list regarding matters and deadlines in the Kwok case (2.3); correspond with D. Barron about same (.1); call with S. Maza regarding same (.1) 2.50 1,015.00 2,537.50 07/13/2023 SM29 Correspond with D. Barron re task list and open issues (.1); call with E. Sutton re task list and open issues (.1) 0.20 1,320.00 264.00

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Date Initials Description Hours Rate Amount 07/14/2023 AB21 Update call with L. Despins, N. Bassett, A. Luft, D. Barron, S. Maza, W. Farmer, , E. Sutton regarding Kwok case and next steps 2.20 1,625.00 3,575.00 07/14/2023 DM26 Update critical dates calendar and send outlook reminders (.5); review upcoming filing deadlines and share with working group (.2) 0.70 540.00 378.00 07/14/2023 DEB4 Prepare agenda for all hands call regarding pending and upcoming litigation 0.50 1,320.00 660.00 07/14/2023 DEB4 Call with L. Despins, N. Bassett, A. Luft, S. Maza, W. Farmer, , E. Sutton and A. Bongartz regarding litigation plan and related issues/task list 2.20 1,320.00 2,904.00 07/14/2023 ECS1 Call with L. Despins, N. Bassett, A. Bongartz, S. Maza, A. Luft, D. Barron, W. Farmer and regarding upcoming matters in Kwok case, strategy, deadlines 2.20 1,015.00 2,233.00 07/14/2023 ECS1 Continue to prepare issues/task list regarding matters and deadlines in the Kwok case 0.70 1,015.00 710.50 07/14/2023 LAD4 Prepare agenda for team call (.70); handle same with A. Bongartz, N. Bassett, S. Maza, D. Barron, A. Luft, E. Sutton, W. Farmer, re: next steps (2.20) 2.90 1,860.00 5,394.00 07/14/2023 AEL2 Call with L. Despins, N. Bassett, A. Bongartz, S. Maza, D. Barron, W. Farmer, , and E. Sutton regarding Kwok case, strategy, deadlines 2.20 1,625.00 3,575.00 07/14/2023 Call with L. Despins, N. Bassett, A. Bongartz, A. Luft, S. Maza, D. Barron, W. Farmer and E. Sutton regarding pending and upcoming case matters and plan for same 2.20 815.00 1,793.00 07/14/2023 NAB Call with L. Despins, A. Bongartz, A. Luft, S. Maza, D. Barron, W. Farmer, , E. 2.20 1,625.00 3,575.00

Sutton regarding litigation tasks and case

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Date Initials Description Hours Rate Amount 07/14/2023 SM20 Constant to and talk with E 2.30 1,320.00 3,004.00 07/14/2023 SM29 Case strategy and update call with E.

, L. Despins, D. Barron, A. Bongartz, N. Bassett, A Luft 2.20 1,320.00 2,904.00 07/14/2023 WCF Call with L. Despins, N. Bassett, A.

litigation plan and upcoming case matters 2.20 1,235.00 2,717.00 07/16/2023 NAB Correspond with W. Farmer regarding case updates and litigation issues (.3); correspond with L. Despins regarding same (.2) 0.50 1,625.00 812.50 07/17/2023 AB21 Update list of open issues and workstreams 0.30 1,625.00 487.50 07/17/2023 DM26 Update critical dates calendar and send

07/17/2023 ECS1 Call with P. Linsey (NPM) regarding open matters and upcoming deadlines 0.20 1,015.00 203.00

pending appeals, and related issues/tasks 0.20 1,015.00 203.00 07/17/2023 Call with W. Farmer, P. Linsey and E.

adversary proceedings and appeals 0.20 815.00 163.00 07/17/2023 WCF Correspond with E. Sutton and

appeals and related issues/tasks (.3); call

appellate and discovery deadlines (.2) 0.50 1,235.00 617.50 07/18/2023 DM26 Update critical dates calendar and send

07/18/2023 NAB Correspond with W. Farmer and L. Despins

pending appeals (.2) 0.40 1,625.00 650.00 Date Initials Description Hours Rate Amount 07/19/2023 DM26 Update critical dates calendar and send

07/20/2023 AB21 Update list of open issues and workstreams 0.20 1,625.00 325.00 07/20/2023 DM26 Update critical dates calendar and send

07/21/2023 DM26 Update critical dates calendar and send

07/21/2023 JK21 Correspond with E. Sutton regarding certificate of service for template to use

07/24/2023 AB21 Update list of open issues and workstreams 0.10 1,625.00 162.50 07/24/2023 DM26 Update critical dates calendar and send

07/24/2023 LAD4 T/c S. Sarnoff (OMM) re: update 0.40 1,860.00 744.00 07/25/2023 DM26 Update critical dates calendar and send outlook reminders (.7); prepare draft notices

(1.0); review upcoming filing deadlines and share with working group (.2) 1.90 540.00 1,026.00 07/26/2023 DM26 Email W. Farmer re: case no. 23cv102

appearance regarding district court case no. 23mc62 (.7); update critical dates calendar

07/27/2023 DM26 Update critical dates calendar and send

Date Initials Description Hours Rate Amount 07/28/2023 DM26 Update critical dates calendar and send

07/30/2023 AB21 Update list of open issues and workstreams 0.20 1,625.00 325.00 07/31/2023 AB21 Update list of open issues and workstreams 0.20 1,625.00 325.00 07/31/2023 DM26 File via the Court's CM/ECF system certain notices of appearance regarding adversary proceeding case no. 23-5018 0.60 540.00 324.00 07/31/2023 DM26 Update critical dates calendar and send

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632 Subtotal: B110 Case Administration 52.00 52,636.50

07/03/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review recent filings in Despins v. Mei Guo case and update working group re same (.1); review related case dockets regarding recent

07/03/2023 DM26 Research certain procedural filings

chapter 11 cases for 1.50 540.00 810.00 07/05/2023 DM26 Review recent filings in Kwok case and update working group re same (.9); review recent filings in Despins v. Bravo Luck case

working group re same (.2); review related case dockets regarding recent filings (.5) 1.60 540.00 864.00 Date Initials Description Hours Rate Amount 07/06/2023 DM26 Review recent filings in Kwok case and update working group re same (.6); review

same (1.0); review recent filings in certain

dockets regarding recent filings (.5) 2.30 540.00 1,242.00 07/07/2023 AB21 Review chapter 11 docket update and recent

07/07/2023 DM26 Review recent filings in Kwok case and update working group re same (.8); review

same (.9); review recent filings in Mei Guo v. Despins Connecticut District Court case and update working group re same (.2); review related case dockets regarding recent

07/10/2023 DM26 Review recent filings in Kwok case and update working group re same (.6); review

same (.8); review recent filings in Kwok v.

working group re same (.2); review related case dockets regarding recent filings (.5) 2.10 540.00 1,134.00 07/11/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review

update working group re same (.4); review

same for working group review (.4); review related case dockets re: recent filings (.4) 2.00 540.00 1,080.00 Date Initials Description Hours Rate Amount 07/12/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review

update working group re same (.3); review related case dockets regarding recent filings

07/13/2023 AB21 Review chapter 11 docket update and recent

07/13/2023 DM26 Review recent filings in Kwok case and update working group re same (.9); review

same (.3); review recent filings in USA v.

and update working group re same (.1);

related case dockets regarding recent filings

07/14/2023 DM26 Review recent filings in Kwok case and update working group re same (.7); review

same (.9); review recent filings in USA v.

regarding recent filings (.5) 2.20 540.00 1,188.00 07/17/2023 DM26 Review recent filings in Kwok case and update working group re same (.6); review

update working group re same (.5); review related case dockets regarding recent filings

Date Initials Description Hours Rate Amount 07/18/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review recent filings in Despins v. Mei Guo case and update working group re same (.1); research certain requested case documents (.6); review additional related case dockets regarding recent filings (.5) 1.60 540.00 864.00 07/19/2023 AB21 Review chapter 11 docket update and recent

07/19/2023 DM26 Review recent filings in Kwok case and update working group re same (.8); review

same for working group review (.5) 2.10 540.00 1,134.00 07/20/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review

dockets regarding recent filings (.5) 1.10 540.00 594.00 07/21/2023 DM26 Review recent filings in Kwok case and update working group re same (.6); review

same (.4); review related case dockets re: recent filings (.5); research pleadings relating to HK Parties and Vartan on sanctions (.6);

regarding same (.1) 2.20 540.00 1,188.00 07/24/2023 DM26 Review recent filings in Kwok case and update working group re same (.6); review

update working group re same (.6); review related case dockets regarding recent filings

Date Initials Description Hours Rate Amount 07/25/2023 DM26 Review recent filings in Kwok case and update working group re same (.7); review

update working group re same (.8); review related case dockets regarding recent filings

07/26/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review

update working group re same (.7); prepare unredacted exhibits related to case no. 23ap5018 for local counsel (.6); research regarding certain requested case documents (.6); review related case dockets regarding recent filings (.5) 2.80 540.00 1,512.00 07/27/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review

regarding recent filings (.5) 1.70 540.00 918.00 07/28/2023 DM26 Review recent filings in Kwok case and update working group re same (.6); review

update working group re same (.9); review

update working group re same (.2); review main case docket and adversary proceeding

related case dockets regarding recent filings

07/31/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review

regarding recent filings (.6) 1.70 540.00 918.00 Date Initials Description Hours Rate Amount Subtotal: B113 Pleadings Review 40.80 22,574.50

07/09/2023 DM26 Draft agenda of matters set for 7/11/23

regarding same (.1) 4.50 540.00 2,430.00 07/10/2023 DM26 Prepare reference materials for 7/11/23

07/13/2023 DM26 Prepare draft agenda of matters scheduled for 7/18/23 hearing (4.3); prepare index of reference materials for hearing (.7) 5.00 540.00 2,700.00 07/16/2023 DM26 Update draft agenda of matters set for

07/17/2023 AB21 Prepare hearing notes for hearing on Epiq fee application (0.6); correspond with L. Despins regarding same (0.1); calls with R.

Subtotal: B155 Court Hearings 18.00 10,588.00

07/05/2023 AB21 Review PH May fee statement (2.6); calls with D. Barron regarding same (0.2);

regarding same (0.1); correspond with W.

D. Barron, N. Bassett, A. Luft, K. Catalano, W. Farmer, E. Sutton, K. Traxler, J. Kuo) regarding new matter numbers (0.1) 3.20 1,625.00 5,200.00 07/05/2023 DEB4 Conferences with A. Bongartz regarding May fee statement 0.20 1,320.00 264.00 Date Initials Description Hours Rate Amount 07/06/2023 AB21 Review PH March, April, and May fee statements (3.5); correspond with J. Kosciewicz regarding same (0.1); call with S. Maza regarding same (0.3) 3.90 1,625.00 6,337.50 07/06/2023 SM29 Call with A. Bongartz re time entries and new client matter numbers 0.30 1,320.00 396.00 07/07/2023 AB21 Revise PH March, April and May fee statements (2.9); correspond with D. Barron regarding same (0.2); correspond with J. Kosciewicz regarding same (0.1);

07/10/2023 AB21 Correspond with D. Barron regarding PH March and April fee statements (0.3); correspond with N. Bassett regarding same (0.1); revise same (0.2) 0.60 1,625.00 975.00 07/11/2023 AB21 Review draft motion for approval of interim compensation procedures (0.4); call with D. Barron regarding time entries for PH March and April fee statements (0.3) 0.70 1,625.00 1,137.50 07/11/2023 DEB4 Conference with A. Bongartz regarding

07/11/2023 KAT2 Prepare parts of second interim fee

07/12/2023 AB21 Revise interim compensation procedures motion (1.8); calls with P. Linsey (Neubert) regarding same (0.3); correspond with P. Linsey and L. Despins regarding same (0.1) 2.20 1,625.00 3,575.00 07/12/2023 AB21 Revise PH March and April time entries (0.4); call with A. Luft regarding same (0.6);

regarding same (0.1) 1.30 1,625.00 2,112.50 07/12/2023 KAT2 Prepare parts of second interim fee

Date Initials Description Hours Rate Amount 07/12/2023 AEL2 Call with A. Bongartz re: time entries for March and April fee statements 0.60 1,625.00 975.00 07/13/2023 AB21 Correspond with N. Bassett regarding PH fee statements (0.1); revise same (0.1) 0.20 1,625.00 325.00 07/13/2023 AB21 Analyze interim compensation procedures

(0.6); call with P. Linsey regarding same (0.1); revise same (0.3) 1.70 1,625.00 2,762.50 07/13/2023 KAT2 Prepare parts of second interim fee application (1.2); prepare response to UST Appendix B questions (.2); correspond with C. Edge regarding information for interim fee application (.1) 1.50 1,025.00 1,537.50 07/13/2023 LAD4 Review/edit interim comp motion 0.60 1,860.00 1,116.00 07/14/2023 KAT2 Prepare parts of second interim fee application, exhibits, supporting declaration, and proposed order (1.6); correspond with A. Bongartz regarding same (.1);

Appendix B information for fee application

07/15/2023 AB21 Review PH May fee statement 2.00 1,625.00 3,250.00 07/17/2023 AB21 Review PH May fee statement (0.4); call with A. Luft regarding same (0.2); call with D. Barron regarding same (0.2); correspond

07/17/2023 DEB4 Conference with A. Bongartz regarding May

07/17/2023 KAT2 Review interim compensation motion 0.20 1,025.00 205.00 07/17/2023 AEL2 Call with A. Bongartz re: May fee statement 0.20 1,625.00 325.00 07/19/2023 AB21 Review PH June fee statement 3.10 1,625.00 5,037.50 07/20/2023 AB21 Revise PH June fee statement 2.50 1,625.00 4,062.50 Date Initials Description Hours Rate Amount 07/20/2023 KAT2 Revise PH second interim fee application

regarding June services and related U.S. Trustee request (.1) 0.30 1,025.00 307.50 07/21/2023 AB21 Review PH June fee statement (1.2); calls with D. Barron regarding same (0.3);

(0.4); correspond with N. Bassett regarding

regarding same (0.1); correspond with W.

with C. Edge regarding same (0.2) 2.40 1,625.00 3,900.00 07/21/2023 DEB4 Conference with A. Bongartz regarding June fee statement 0.30 1,320.00 396.00 07/21/2023 AEL2 Correspond with A. Bongartz re: fee application edits 0.40 1,625.00 650.00 07/24/2023 AB21 Prepare parts of PH second interim fee application (3.4); correspond with E. Sutton regarding same (0.1) 3.50 1,625.00 5,687.50 07/25/2023 AB21 Review PH March fee statement (1.7); correspond with L. Despins regarding same (0.1); review PH April fee statement (1.4);

statements (0.2); call with C. Edge regarding

interim fee application (1.8); correspond with D. Barron regarding same (0.4) 5.70 1,625.00 9,262.50 07/25/2023 ECS1 Correspond with A. Bongartz regarding depositions in connection with PH interim

07/26/2023 AB21 Review PH March, April, and May 2023 fee statements (1.3); correspond with C. Edge regarding same (0.2); prepare parts of PH second interim fee application (3.4);

(0.1); call with N. Bassett regarding same (0.1); correspond with D. Barron regarding

Date Initials Description Hours Rate Amount 07/26/2023 DEB4 Analyze fee statements and related

interim fee application 4.40 1,320.00 5,808.00 07/26/2023 NAB Call with A. Bongartz regarding interim fee application (.1); correspond with A. Bongartz regarding same (.2) 0.30 1,625.00 487.50 07/27/2023 AB21 Correspond with L. Despins regarding PH interim fee application (0.3); prepare parts of same (1.9); call with D. Barron regarding

regarding same (0.1); correspond with N.

(0.1); review March, April, and May PH fee statements (1.0); correspond with C. Edge regarding same (0.1) 3.80 1,625.00 6,175.00 07/27/2023 DEB4 Prepare sections of interim fee application 4.80 1,320.00 6,336.00 07/27/2023 DEB4 Conference with A. Bongartz regarding interim fee application 0.20 1,320.00 264.00 07/27/2023 DEB4 Correspond with W. Farmer regarding Jimang Lio lawsuit in connection with fee

07/28/2023 AB21 Revise PH June fee statement (0.8);

(0.1); revise PH interim fee application (0.8); correspond with N. Bassett regarding same

07/28/2023 DEB4 Prepare sections of interim fee application 0.80 1,320.00 1,056.00 07/30/2023 AB21 Prepare parts of PH interim fee application 1.30 1,625.00 2,112.50 07/30/2023 KAT2 Correspond with D. Gonzalez regarding fee

07/31/2023 AB21 Call with K. Traxler regarding notice of PH rate adjustment (0.1); revise same (0.1);

regarding same (0.1) 0.30 1,625.00 487.50 Date Initials Description Hours Rate Amount 07/31/2023 AB21 Review and prepare parts of PH second interim fee application (1.8); calls with C. Edge regarding same (0.2); correspond with L. Despins regarding same (0.2); correspond with K. Traxler regarding same (0.1); correspond with N. Bassett regarding same

07/31/2023 KAT2 Correspond with D. Gonzalez regarding fee matters (.1); correspond with A. Bongartz regarding same and change in rates (.1); prepare notice of change in rates (.4); call with A. Bongartz regarding same (.1) 0.70 1,025.00 717.50 07/31/2023 NAB Prepare parts of fee application (1.7);

Subtotal: B160 Fee/Employment Applications 73.70 112,703.50

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632 B165 Fee/Employment Applications for Other Professionals

07/03/2023 AB21 Correspond with D. White (EOCS) regarding EOCS invoice 0.10 1,625.00 162.50

07/05/2023 AB21 Correspond with J. Kuo regarding filing of

regarding same (0.1) 0.20 1,625.00 325.00 07/05/2023 JK21 Prepare for electronic filing notice of filing

(0.2); electronically file with the court notice

07/06/2023 AB21 Call with H. Claiborn (U.S. Trustee) regarding Epiq fee application (0.2);

regarding same (0.2); correspond with H. Claiborn regarding same (0.3) 0.70 1,625.00 1,137.50 Date Initials Description Hours Rate Amount 07/07/2023 AB21 Correspond with L. Despins regarding

H. Claiborn (U.S. Trustee) regarding same

07/10/2023 AB21 Correspond with H. Claiborn (US Trustee) regarding Epiq fee application 0.10 1,625.00 162.50 07/10/2023 JK21 Prepare notice of filing of revised AAGL proposed order (0.4); electronically file with the court notice of filing of revised AAGL

service of same (0.2) 0.90 540.00 486.00 07/11/2023 LAD4 T/c M. Kennedy (Chilmark) re: forensic

07/13/2023 LAD4 Interview Teneo team as forensic

07/14/2023 AB21 Correspond with H. Claiborn (U.S. Trustee)

(0.1); calls and correspond with P. Linsey (Neubert) regarding same (0.1); correspond

(Bohonnon Law) regarding same (0.1) 0.40 1,625.00 650.00 07/14/2023 DEB4 Correspond with A. Luft regarding investigator retention 0.10 1,320.00 132.00 07/17/2023 AB21 Call with P. Linsey (Neubert) regarding fee applications and next steps (0.3); call with

Harneys fee application (0.2) 0.50 1,625.00 812.50 07/17/2023 DEB4 Calls with E. Sutton regarding forensic accountant retention matters 0.20 1,320.00 264.00 07/17/2023 DEB4 Correspond with J. Voss (FRA) regarding forensic accountant retention issues 0.10 1,320.00 132.00 07/17/2023 DEB4 Correspond with A. Luft, N. Bassett and P. Kelker (Risk Advisory) regarding potential

07/17/2023 ECS1 Prepare parties in interest list for forensic accounting firms (.7); call with D. Barron

Date Initials Description Hours Rate Amount 07/17/2023 ECS1 Prepare care package with bank accounts

discovery (.1); correspond with , J.

with D. Barron about same (.1) 0.30 1,015.00 304.50 07/17/2023 AEL2 Call with Risk Advisory re: potential investigative work 0.70 1,625.00 1,137.50 07/18/2023 AB21 Correspond with L. Despins regarding hearing on Epiq fee application (0.1); call

(0.1); correspond with L. Despins regarding

07/18/2023 ECS1 Prepare care package with bank account/statement information produced in

, J. Kuo and D. Barron about same (.1) 0.20 1,015.00 203.00 07/19/2023 ECS1 Prepare care package with (and summarizing) bank accounts and statements produced in Kwok discovery (.1); correspond with UnitedLex about same (.2) 0.30 1,015.00 304.50 07/19/2023 AEL2 Call with J. Voss re: retention and interested

07/20/2023 AB21 Review draft Bohonnon retention application (0.1); call and correspond with D. Skalka (Neubert) regarding same (0.1) 0.20 1,625.00 325.00 07/21/2023 AB21 Revise Bohonnon retention application (0.3); correspond with L. Despins (0.2);

Law) regarding supporting declaration (0.1) 0.70 1,625.00 1,137.50 07/21/2023 JK21 Correspond with E. Sutton regarding documents for forensic accountant 0.30 540.00 162.00 07/24/2023 AB21 Call and correspond with P. Linsey

retention application 0.10 1,625.00 162.50 07/24/2023 AB21 Call with S. Martinez (Alix) regarding retention of forensic accountant 0.30 1,625.00 487.50 Date Initials Description Hours Rate Amount 07/24/2023 DEB4 Conference with A. Luft, L. Despins and Kroll regarding potential retention 0.60 1,320.00 792.00 07/24/2023 DEB4 Correspond with E. Esses (Kroll) regarding list of interested parties 0.10 1,320.00 132.00 07/24/2023 ECS1 Correspond with A. Bongartz regarding parties in interest list for Kroll 0.10 1,015.00 101.50 07/24/2023 LAD4 Review/comment on retention of forensic accountants (1.30); interview Kroll re: same with D. Barron and A. Luft (.60) 1.90 1,860.00 3,534.00 07/24/2023 AEL2 Meeting with Kroll, D. Barron, L. Despins re: potential forensic accounting analysis 0.60 1,625.00 975.00 07/31/2023 LAD4 Review/edit forensic accountant retention terms (1.80); t/c S. Sarnoff (OMM) re: same and update (.40); t/c A. Pfeiffer (Kroll) re: final call (.40) 2.60 1,860.00 4,836.00

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Subtotal: B165 Fee/Employment Applications for 16.60 24,938.00 Other Professionals

07/10/2023 AB21 Review draft motion to extend removal deadline (0.2); correspond with L. Despins regarding same (0.1); correspond with P. Linsey (Neubert) regarding same (0.1) 0.40 1,625.00 650.00

Subtotal: B191 General Litigation 0.40 650.00

07/03/2023 AB21 Correspond with L. Despins and R.

transfer to interest-bearing account 0.20 1,625.00 325.00

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Date Initials Description Hours Rate Amount

07/14/2023 AB21 Correspond with H. Claiborn (U.S. Trustee)

(0.4); correspond with L. Despins regarding

regarding same (0.1); correspond with T. Sadler regarding same (0.1); call with D. Barron regarding same (0.1) 1.20 1,625.00 1,950.00 07/14/2023 DEB4 Conference with A. Bongartz regarding bank accounts and surety bonds 0.10 1,320.00 132.00 07/17/2023 AB21 Correspond with L. Despins regarding trustee bond (0.1); correspond with T. Sadler regarding same (0.2) 0.30 1,625.00 487.50 07/18/2023 AB21 Correspond with T. Sadler regarding pricing quote for trustee bond (0.2); review related application (0.2) 0.40 1,625.00 650.00 07/18/2023 TS21 Correspond with Levine Company re surety bond premium quote (.3); call with Levine Company re same (.2) 0.50 1,175.00 587.50 07/19/2023 AB21 Correspond with T. Sadler regarding wire transfer for Epiq fees 0.10 1,625.00 162.50 07/20/2023 AB21 Correspond with T. Sadler regarding trustee

regarding same (0.1) 0.30 1,625.00 487.50 07/20/2023 AB21 Correspond with T. Sadler regarding wire transfers for Pullman fees and EOCS fees 0.10 1,625.00 162.50 07/20/2023 TS21 Correspond with A. Bongartz re surety bond (.1); correspond with surety provider

Dexter White invoices (.6) 1.20 1,175.00 1,410.00 07/24/2023 AB21 Correspond with T. Sadler regarding update on pricing quote for trustee bond 0.10 1,625.00 162.50 07/24/2023 TS21 Correspond with L. Despins, A. Bongartz

07/25/2023 TS21 Correspond with Levine Corporation re

07/10/2023 AB21 Correspond with J. Gervais (U.S. Trustee)

monthly operating report 0.10 1,625.00 162.50 07/18/2023 DEB4 Correspond with T. Sadler regarding MOR 0.20 1,320.00 264.00 07/19/2023 DEB4 Correspond with T. Sadler regarding MOR (0.2); review same (0.3) 0.50 1,320.00 660.00 07/19/2023 TS21 Prepare June monthly operating report

07/20/2023 TS21 Correspond with L. Despins and D. Mohamed re monthly operating report 0.20 1,175.00 235.00 07/21/2023 DM26 File via the Court's CM/ECF system monthly operating report by Trustee (.1); correspond with local counsel re service of

07/31/2023 DEB4 Correspond with L. Despins regarding

Subtotal: B211 Financial Reports (Monthly

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Date Initials Description Hours Rate Amount 07/26/2023 AB21 Correspond with L. Despins regarding trustee bond (0.1); correspond with H. Clayborn (U.S. Trustee) regarding same (0.1) 0.20 1,625.00 325.00 07/28/2023 AB21 Correspond with T. Sadler regarding update on trustee bond 0.10 1,625.00 162.50 07/28/2023 TS21 Correspond with A. Bongartz and L. Despins re surety bond 0.10 1,175.00 117.50 07/31/2023 AB21 Correspond with T. Sadler regarding trustee bond 0.10 1,625.00 162.50 Subtotal: B210 Business Operations 5.50 7,872.00 B211 Financial Reports (Monthly Operating Reports)

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Date Initials Description Hours Rate Amount

07/02/2023 SM29 Review and revise DIP motion from

07/03/2023 Prepare parts of DIP motion and incorporate S. Maza comments in same 6.80 915.00 6,222.00 07/03/2023 SM29 Review and revise DIP motion 2.00 1,320.00 2,640.00 07/04/2023 Prepare parts of DIP motion 1.90 915.00 1,738.50 07/05/2023 AC43 Review draft DIP motion for key DIP terms (0.8); call with S. Maza regarding DIP credit agreement and motion (0.3) 1.10 1,725.00 1,897.50 07/05/2023 SM29 Call with A. Cota re DIP credit agreement and motion (.3); prepare notes for same (.1) 0.40 1,320.00 528.00 07/07/2023 Review precedent DIP orders (.4); prepare final DIP order (1.2) 1.60 915.00 1,464.00 07/07/2023 DM26 Research regarding certain precedent DIP

07/10/2023 AB21 Correspond with L. Despins regarding interdebtor DIP motion (0.1); conferences with S. Maza regarding same (1.0);

07/10/2023 SM29 Revise DIP motion (1.3); prepare issues list regarding same (.5); analyze authority re same (.3); conferences with A. Bongartz re same (1.0); correspond with L. Despins re same (.4); correspond with A. Cota re credit

07/11/2023 AC43 Review DIP terms and structure (0.9); review precedent credit agreement (0.4);

structure (0.5) 1.80 1,725.00 3,105.00 07/11/2023 Review precedent DIP orders (.4); prepare final DIP order (.7) 1.10 915.00 1,006.50 Date Initials Description Hours Rate Amount 07/11/2023 MG21 Correspond with A. Cota regarding DIP

agreements (1.1); draft parts of DIP credit agreement (.60) 2.30 1,290.00 2,967.00 07/11/2023 SM29 Correspond with M. Grabis re DIP credit

07/12/2023 Continue to prepare draft DIP order 5.90 915.00 5,398.50 07/13/2023 Review and revise draft DIP order (1.5);

07/13/2023 MG21 Continue to draft DIP credit agreement 2.00 1,290.00 2,580.00 07/14/2023 MG21 Draft parts of DIP credit agreement 1.00 1,290.00 1,290.00 07/14/2023 SM29 Revise DIP motion and order 0.80 1,320.00 1,056.00 07/17/2023 AB21 Review draft inter-debtor DIP motion (0.6); call with S. Maza regarding same (0.4) 1.00 1,625.00 1,625.00 07/17/2023 Correspond with J. Kuo re lien searches (0.2); telephone conference with S. Maza on motion to limit service of DIP motion (0.1) 0.30 915.00 274.50 07/17/2023 ECS1 Correspond with S. Maza regarding motion to limit notice in connection with section

07/17/2023 JK21 Correspond with S. Maza regarding lien searches for Genever entities (0.2); review

07/17/2023 MG21 Draft parts of DIP credit agreement 1.50 1,290.00 1,935.00 07/17/2023 SM29 Email J. Kuo re DIP liens search 0.10 1,320.00 132.00 07/17/2023 SM29 Call with A. Bongartz re DIP financing (.4); revise DIP motion and order (.3); email M. Grabis re DIP credit agreement (.2); review leases in connection with same (.5);

limit service of DIP motion (.1); call with

Date Initials Description Hours Rate Amount 07/18/2023 Draft motion to limit service of the DIP motion and corresponding proposed order 2.80 915.00 2,562.00 07/18/2023 MG21 Draft parts of DIP credit agreement (1.00);

(.30); correspond with A. Cota and S. Maza regarding draft credit agreement (.20) 1.50 1,290.00 1,935.00 07/18/2023 SM29 Preliminary review of DIP credit agreement (.3); email M. Grabis re same and security

07/18/2023 SM29 Correspond with re DIP motion and

email from M. Grabis re DIP motion (.1) 0.30 1,320.00 396.00 07/19/2023 AB21 Call with S. Maza regarding interdebtor DIP

07/19/2023 AC43 Review and comment on DIP credit

connection with same (0.7) 1.80 1,725.00 3,105.00 07/19/2023 MG21 Review credit agreement (.90); related correspondence with S. Maza (.30) 1.20 1,290.00 1,548.00 07/19/2023 SM29 Review DIP credit agreement (3.0); call with A. Bongartz re same and DIP motion (.3); correspond with M. Grabis re same (.2); review lease documents in connection with security agreement (.5); analyze authority re same (1.7); correspond with A. Bongartz re same (.2); email L. Despins re same (.2); revise DIP motion and order (1.1) 7.20 1,320.00 9,504.00 07/20/2023 AB21 Call with S. Maza regarding interdebtor DIP

regarding same (0.1) 0.30 1,625.00 487.50 07/20/2023 AC43 Review changes to DIP credit agreement and provide comments on same (.30); analyze DIP credit agreement issues (1.10);

07/20/2023 Revise motion to limit service of DIP

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Date Initials Description Hours Rate Amount

07/20/2023 LAD4 Review/edit DIP motion (1.20); t/c S. Maza re: same (.30) 1.50 1,860.00 2,790.00 07/20/2023 MG21 Prepare parts of DIP credit agreement (2.4); related correspondence with A. Cota and S.

07/20/2023 SM29 Call with L. Despins re DIP motion

incorporate L. Despins comments (1.9);

same (.1); revise DIP motion to incorporate further comments from L. Despins (.5); call

revised DIP credit agreement (.3); correspond with M. Grabis re same (.1);

07/21/2023 Review Sherry Netherland related documents 1.30 915.00 1,189.50 07/21/2023 Review Sherry Netherland documents related to maintenance fund 0.50 915.00 457.50 07/21/2023 LAD4 Review/edit re-draft of DIP motion and analyze open issues re: same (3.10); t/c S.

(Pullman) re: DIP financing issues (.50) 3.60 1,860.00 6,696.00 07/21/2023 MG21 Review and revise DIP credit agreement (1.20); related correspondence with S. Maza

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Date Initials Description Hours Rate Amount

07/21/2023 SM29 Revise DIP motion (.5); revise DIP credit

comments from L. Despins (.2); email L. Despins re same and motion to limit notice re same (.1); correspond with M. Grabis re DIP credit agreement (.2); correspond with

(.3); correspond with A. Bongartz re same

(.2); email B. Langer re same (.2); analyze authority re same (1.0) 5.00 1,320.00 6,600.00 07/22/2023 AB21 Correspond with L. Despins regarding interdebtor DIP motion (0.1); review same

regarding same (0.1) 0.50 1,625.00 812.50 07/22/2023 AC43 Review revised DIP credit agreement (.70); correspond with M. Grabis on same (.20) 0.90 1,725.00 1,552.50 07/24/2023 AB21 Call with L. Despins, S. Maza regarding

attorney related to same (0.2); correspond

regarding same (0.1) 0.70 1,625.00 1,137.50 07/24/2023 JK21 Correspond with M. Grabis and S. Maza regarding lien search results 0.20 540.00 108.00 07/24/2023 LAD4 T/c S. Maza, A. Bongartz and C. Abrehart (Genever BVI director) re: DIP financing 0.40 1,860.00 744.00 07/24/2023 MG21 Review lien searches (.1); review updated DIP credit agreement (.2); correspond with S. Maza and A. Cota regarding same (.1) 0.40 1,290.00 516.00 07/24/2023 SM29 Call with L. Despins, A. Bongartz, C.

power of attorney in connection with same

Case 22-50073-Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 526 of

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Date Initials Description Hours Rate Amount

07/24/2023 SM29 Review DIP credit agreement and proposed order (1.3); correspond with M. Grabis and J. Kuo re lien searches (.2) 1.50 1,320.00 1,980.00 07/25/2023 AB21 Correspond with S. Maza regarding update on interdebtor DIP motion (0.1);

regarding same (0.1); correspond with P. Friedman (O'Melveny) regarding same (0.1) 0.30 1,625.00 487.50 07/26/2023 AB21 Correspond with S. Millman (Stroock) regarding interdebtor DIP motion (0.1); call with S. Maza regarding same and DIP order

07/26/2023 SM29 Revise DIP motion in connection with

authority re same (.4); email L. Despins re

motion and order (.1) 1.30 1,320.00 1,716.00 07/27/2023 AB21 Call with S. Maza regarding update on interdebtor DIP motion 0.10 1,625.00 162.50 07/27/2023 Review and revise DIP financing motion

07/27/2023 MG21 Correspond with S. Maza regarding DIP

07/27/2023 SM29 Call with A. Bongartz re DIP motion (.1); email , M. Grabis re same (.1) 0.20 1,320.00 264.00 07/28/2023 Review and revise motion to limit service,

07/31/2023 AB21 Call with L. Despins and S. Millman (Stroock) regarding interdebtor DIP (0.7);

(0.3); analyze related issues (0.3); correspond with L. Despins regarding same

07/31/2023 LAD4 T/c S. Millman (S-N counsel) and A. Bongartz re: DIP financing 0.70 1,860.00 1,302.00 07/31/2023 MG21 Correspond with A. Bongartz regarding updates to DIP credit agreement 0.20 1,290.00 258.00 Case 22-50073-Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 527 of

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

Date Initials Description Hours Rate Amount Subtotal: B230 Financing/Cash Collections 99.20 125,576.50 B310 Claims Administration and Objections 07/10/2023 JK21 Correspond with E. Sutton regarding asserted claims 0.30 540.00 162.00 07/12/2023 DEB4 Correspond with R. Amporfro (Epiq) regarding claims register 0.10 1,320.00 132.00 07/12/2023 DEB4 Correspond with A. Bongartz regarding claims register 0.10 1,320.00 132.00 Subtotal: B310 Claims Administration and Objections 0.50 426.00 Total 310.80 362,796.50

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 16.30 1,860.00 30,318.00 AC43 Alex Cota Partner 7.20 1,725.00 12,420.00 NAB Nicholas A. Bassett Partner 5.20 1,625.00 8,450.00 AEL2 Luft, Avi E. Of Counsel 4.80 1,625.00 7,800.00 AB21 Alex Bongartz Of Counsel 70.90 1,625.00 115,212.50 KAT2 Katherine A. Traxler Of Counsel 5.90 1,025.00 6,047.50 DEB4 Douglass E. Barron Associate 17.10 1,320.00 22,572.00 SM29 Shlomo Maza Associate 37.00 1,320.00 48,840.00 MG21 Maria Grabis Associate 14.40 1,290.00 18,576.00 WCF Will C. Farmer Associate 2.70 1,235.00 3,334.50 TS21 Tess Sadler Associate 4.90 1,175.00 5,757.50 ECS1 Ezra C. Sutton Associate 9.70 1,015.00 9,845.50

DM26 David Mohamed Paralegal 79.50 540.00 42,930.00 JK21 Jocelyn Kuo Paralegal 3.40 540.00 1,836.00

Date Description Quantity Rate Amount 07/05/2023 Photocopy Charges 96.00 0.08 7.68 07/05/2023 Photocopy Charges 120.00 0.08 9.60 07/07/2023 Photocopy Charges 792.00 0.08 63.36 07/07/2023 Photocopy Charges 120.00 0.08 9.60 07/10/2023 Photocopy Charges 264.00 0.08 21.12 07/10/2023 Photocopy Charges 429.00 0.08 34.32 07/10/2023 Photocopy Charges (Color) 1,264.00 0.20 252.80 07/11/2023 Photocopy Charges 3,186.00 0.08 254.88 07/11/2023 Photocopy Charges (Color) 96.00 0.20 19.20 07/17/2023 Photocopy Charges 146.00 0.08 11.68 07/17/2023 Photocopy Charges 171.00 0.08 13.68 07/17/2023 Photocopy Charges 49.00 0.08 3.92 07/31/2023 Photocopy Charges 636.00 0.08 50.88 07/01/2023 Computer Search (Other) 3.42

07/03/2023 Computer Search (Other) 19.80 07/04/2023 Computer Search (Other) 0.09 07/05/2023 Postage/Express Mail - First Class - US; 14.40 07/05/2023 Postage/Express Mail - First Class - US; 30.24 07/05/2023 Computer Search (Other) 13.95 07/06/2023 Computer Search (Other) 10.08 07/07/2023 Postage/Express Mail - First Class - US; 30.24 Case 22-50073-Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 528 of

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632 Case 22-50073-Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 529 of

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 30

07/07/2023 Postage/Express Mail - First Class - US; 30.24

07/07/2023 Computer Search (Other) 28.89

07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; ; HCHK Technologies, Inc; 251 Little Falls Drive; WILMINGTON, DE 198081674 ;

07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; ; HCHK Technologies, Inc; 251 Little Falls Drive; WILMINGTON, DE 198081674 ;

07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; SARI B PLACONA ESQ; HCHK Technologies, Inc.,; 75 Livingston Avenue, 2nd Floor; ROSELAND, NJ 070683737 ; 1ZA6T1630191440793 (MAN) 23.59 07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; PRIYA CHAUDHRY; c/o ChaudhryLaw PLLC; 147 W. 25th St. 12th Fl; NEW YORK, NY 100017229 ;

07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; ; BRIAN W. HOFMEISTER; 3131 Princeton Pike; LAWRENCEVILLE, NJ 086482201 ;

07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; Alex Lipman; Yanping "Yvette" Wang; c/o Lipman Law PLLC; NEW YORK, NY 100017229 ;

07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; BRIAN

Jareck; 1325 Avenue of the Americas; New York, NY 100196026 ; 1ZA6T1630199621789 (MAN) 23.59 07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023;

07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; Officer, Managing Ge; HCHK Property Management, Inc.; 1209 Orange Street; Wilmington, DE 198011120 ;

07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; ; Joshua I. Sherman, Esq.; 10 Mohawk Drive; Livingston, NJ 070393112 ; 1ZA6T1630193529426 (MAN) 30.28 07/10/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163283; 07/10/2023; ; ANTHONY DIBATTISTA; 45 PARK HILL DR.; HOPEWELL JUNCTION, NY 125335607 ;

07/10/2023 Postage/Express Mail - First Class - US; 26.91 07/10/2023 Postage/Express Mail - First Class - US; 38.16 07/10/2023 Computer Search (Other) 26.46 07/11/2023 Messenger - Requested by Shlomo Maza; City Expeditor Inc. (USD)(JPMSUA); Invoice # 97695 dated 07/16/2023; From: Paul Hastings Llp; To: Connecticut Bankruptcy Court 915 Lafayette Blvd Bridgeport Ct 06604; Order # 1577183 dated

07/11/2023 Computer Search (Other) 32.76 07/12/2023 Computer Search (Other) 10.71 07/13/2023 Computer Search (Other) 178.74 07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023; SARI B

Avenue, 2nd Floor; ROSELAND, NJ 070683737 ;

07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023;

Technologies, Inc.; 251 Little Falls Drive; WILMINGTON, DE 198081674 ;

07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023;

Grand Iason; 565 Fifth Avenue; NEW YORK, NY 100172413 ; 1ZA6T1630190060008 (MAN) 23.59 07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023;

Center; 1209 Orange Street; WILMINGTON, DE 198011120 ; 1ZA6T1630198351251 (MAN) 23.59 07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023; ; BRIAN W. HOFMEISTER; 3131 PRINCETON PIKE; LAWRENCEVILLE, NJ 086482201 ;

07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023; ; RYAN T JARECK ESQ; 1325 Avenue of the Americas; NEW YORK, NY 100196079 ;

07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023; ALEX LIPMAN; c/o Lipman Law PLLC; 147 W. 25th St. 12th Fl; NEW YORK, NY 100017229 ;

07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023; PRIYA CHAUDHRY; c/o ChaudhryLaw; 147 W. 25th St. 12th Fl; NEW YORK, NY 100017229 ;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 33

07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023;

Property and Staffing, In; 251 Little Falls Drive; WILMINGTON, DE 198081674 ;

07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023; 36.62

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Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632 Page 31

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Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632 Page 32 Case 22-50073r-D0c1d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 13Page 5202 of

07/14/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163293; 07/14/2023; ; ANTHONY DIBATTISTA; 45 Park Hill Dr.; HOPEWELL JUNCTION, NY 125335607 ;

07/14/2023 Postage/Express Mail - First Class - US; 20.67 07/14/2023 Computer Search (Other) 25.92

07/18/2023 Search Fee - SPI Corporate Solutions, Inc., Invoice# 104026 Dated 07/18/23, Lien searches regarding Genever Holdings Corporation and

07/18/2023 Local - Meals - Shlomo Maza; 07/10/2023; Restaurant: Sandwich Bar; City: Flushing; Dinner; Number of people: 1; Dinner expense working late

07/18/2023 Computer Search (Other) 12.60 07/19/2023 Computer Search (Other) 26.55

07/20/2023 Postage/Express Mail - Express Mail; 28.75

07/20/2023 Computer Search (Other) 17.01 07/21/2023 Computer Search (Other) 11.16

07/24/2023 Computer Search (Other) 15.93 Case 22-50073r-D0c1d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 13Page 5203 of 486

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2369632

07/25/2023 Computer Search (Other) 16.20

07/26/2023 Computer Search (Other) 20.88 07/27/2023 Computer Search (Other) 51.57 07/28/2023 Local - Taxi - Shlomo Maza; 07/19/2023; From/To: Office/Home ; Service Type: Uber; Time: 20:12; working late on matter 78.13 07/28/2023 Computer Search (Other) 83.52

07/31/2023 Postage/Express Mail - First Class - US; 60.42 Total Costs incurred and advanced \$4,863.56

Total Balance Due - Due Upon Receipt \$367,660.06 Case 22-50073r-D0c1d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 13Page 5204 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$219,121.50

Total Balance Due - Due Upon Receipt \$320,751.82

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-D0c1d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 14Page 5205 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$219,121.50

Total Balance Due - Due Upon Receipt \$320,751.82

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-D0c1d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 14Page 5206 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Wan Kwok Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation \$219,121.50 Date Initials Description Hours Rate Amount

07/13/2023 LAD4 Call with UBS team and Herbert Smith,

Subtotal: B120 Asset Analysis and Recovery 0.50 930.00

07/08/2023 ECS1 Correspond with D. Mohamed regarding agenda for 7/11/23 hearing 0.20 1,015.00 203.00 07/08/2023 NAB Prepare outline for June 12, 2023 hearing 0.20 1,625.00 325.00 07/09/2023 ECS1 Prepare agenda for 7/11/23 hearing 0.30 1,015.00 304.50 07/10/2023 ECS1 Prepare cheat sheet summarizing

for the 7/11/23 hearing (1.4); correspond with D. Barron about same (.1) 1.50 1,015.00 1,522.50 Date Initials Description Hours Rate Amount 07/11/2023 AB21 Correspond with L. Despins regarding reference materials for July 12, 2023 hearing

07/11/2023 ECS1 Prepare hearing notes for July 11, 2023

07/11/2023 AEL2 Attend Zeisler Hudson Diamond motion to withdraw hearing 1.50 1,625.00 2,437.50 07/13/2023 ECS1 Prepare agenda for 7/18/23 hearing regarding GTV and Saraca 0.20 1,015.00 203.00 07/13/2023 ECS1 Review certain submissions to prepare for 7/18/23 hearings and pretrial conference in

07/14/2023 DM26 Update draft 7/18/23 hearing agenda (.2);

regarding rule 2004 motion to compel as it

07/17/2023 DM26 Prepare reference materials for hearing regarding GTV, Saraca and Mitchell (1.5);

07/17/2023 ECS1 Review documents and evidentiary issues

conference in Kwok case 0.90 1,015.00 913.50 07/18/2023 DEB4 Conference with E. Sutton regarding

07/18/2023 AEL2 Attend hearing re: GTV and Saraca 2.20 1,625.00 3,575.00 Subtotal: B155 Court Hearings 11.80 13,049.50 Date Initials Description Hours Rate Amount

07/05/2023 NAB Assess pending litigation 0.20 1,625.00 325.00 07/07/2023 JK21 Update appeals tracking chart 0.40 540.00 216.00 07/07/2023 AEL2 Call with N. Bassett re: upcoming

proceedings and open litigation matters 0.40 1,625.00 650.00 07/07/2023 NAB Call with A. Luft regarding Bravo Luck, Greenwich Land, HCHK, and case issues 0.40 1,625.00 650.00 07/10/2023 AB21 Correspond with L. Despins regarding hearsay rulings in Kwok case 0.20 1,625.00 325.00 07/11/2023 AEL2 Meet with N. Bassett re: discovery and litigation plan for upcoming matters 0.50 1,625.00 812.50 07/11/2023 NAB Conference with A. Luft regarding strategic

adversary proceedings 0.50 1,625.00 812.50 07/12/2023 NAB Correspond with A. Luft regarding open litigation issues, discovery, and next steps in

07/13/2023 JK21 Update appeals tracking chart 0.90 540.00 486.00 07/15/2023 NAB Review email from W. Farmer regarding appellate briefing and deadlines 0.30 1,625.00 487.50 07/15/2023 WCF Review appellate dockets regarding July and August briefing deadlines (.2); call with P. Linsey (NPM) regarding same (.2);

regarding upcoming appellee briefs (.4) 0.80 1,235.00 988.00 07/15/2023 WCF Correspond with E. Sutton and

deadlines and discovery planning 0.30 1,235.00 370.50 07/18/2023 DEB4 Correspond with A. Luft and N. Bassett

07/18/2023 Prepare issues/task list regarding pending adversary proceedings 0.80 815.00 652.00 Date Initials Description Hours Rate Amount 07/19/2023 AEL2 Correspond with N. Bassett regarding discovery and plan re: outstanding motions 0.80 1,625.00 1,300.00 07/21/2023 JK21 Update appeals tracking chart 0.40 540.00 216.00 07/24/2023 ECS1 Call with W. Farmer and P. Linsey (NPM)

07/24/2023 WCF Call with P. Linsey (NPM), E. Sutton

proceedings and appeals (.3); analyze certain issues discussed for next steps (.3) 0.60 1,235.00 741.00 07/31/2023 ECS1 Call with and P. Linsey (NPM)

and appeal filing deadlines 0.10 1,015.00 101.50 07/31/2023 JK21 Update appeals tracking chart 0.40 540.00 216.00 07/31/2023 AEL2 Correspond with N. Bassett re: discovery

07/31/2023 Prepare litigation issues/task list for pending adversary proceedings (.9); call with

07/31/2023 NAB Correspond with A. Luft regarding litigation

appeals and pending litigation matters (.2) 0.60 1,625.00 975.00 Subtotal: B191 General Litigation 10.80 12,876.00 Case 22-50073r-D0c1d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 14Page 5207 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633 Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5208 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633 Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5209 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

07/11/2023 NAB Non-working travel from WDC to Connecticut for M. Levine deposition (Bill

07/12/2023 NAB Non-working travel from New York to

Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5210 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Date Initials Description Hours Rate Amount

07/18/2023 AEL2 Travel back to NY from hearing in CT (Bill

Subtotal: B195 Non-Working Travel 5.20 4,225.00

07/18/2023 AB21 Call with D. Johnson (Edmiston) regarding update on Lady May II and next steps (0.1); analyze same (0.1) 0.20 1,625.00 325.00 07/18/2023 AB21 Correspond with R. Stockil (Yachtzoo) regarding open invoice 0.20 1,625.00 325.00 07/20/2023 AB21 Review application for customs bond for

regarding same (0.2); call with J. Reynolds

regarding same (0.1); correspond with D. Johnson (Edmiston) regarding same (0.1); correspond with J. Reynolds regarding same

07/24/2023 AB21 Review Newport dockage fee statement 0.10 1,625.00 162.50 07/28/2023 AB21 Correspond with R. Stockil (Yachtzoo) regarding Yachtzoo invoice 0.10 1,625.00 162.50 07/31/2023 AB21 Correspond with L. Despins regarding

with R. Stockil (Yachtzoo) regarding open

Subtotal: B210 Business Operations 2.10 3,412.50

07/02/2023 Prepare summary of informant's email regarding Kwok's associates and activities 1.30 815.00 1,059.50 07/03/2023 DM26 Research regarding certain potential Rule

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Date Initials Description Hours Rate Amount

07/03/2023 DEB4 Correspond with A. Luft regarding U.S. Trustee filing on Hudson Diamond 0.30 1,320.00 396.00 07/03/2023 ECS1 Prepare responses to rule 2004 targets

07/05/2023 DEB4 Conference with A. Luft and E. Sutton

withdrawal as counsel 0.40 1,320.00 528.00 07/05/2023 DEB4 Correspond with A. Luft regarding 3

07/05/2023 ECS1 Prepare responses to rule 2004 targets

07/05/2023 ECS1 Call with C. Fornos (Pillsbury), A. Luft, and

rule 2004 production and concerns relating to confidentiality (.3); review issues and notes to prepare for same (.1); follow up call with A. Luft and W. Farmer regarding

07/05/2023 ECS1 Meet and confer call with P. Pileggi (Arent

Almani's rule 2004 requests (.4); follow up call with A. Luft regarding same (.1) 0.50 1,015.00 507.50 07/05/2023 ECS1 Prepare statement and reservation of rights

counsel (1.7); call with A. Luft and D. Barron re same (.4) 2.10 1,015.00 2,131.50 07/05/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.50 1,015.00 507.50 07/05/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and related corporate information 0.20 1,015.00 203.00 Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5212 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Date Initials Description Hours Rate Amount

07/05/2023 AEL2 Call with D. Barron and E. Sutton re:

Diamond withdrawal 0.40 1,625.00 650.00 07/05/2023 AEL2 Correspond with D. Barron re: outstanding rule 2004 investigative requests and next

07/05/2023 AEL2 Revise reply re: Hudson Diamond rule 2004

07/05/2023 AEL2 Meet and confer with counsel for G Club (C. Fornos, Pillsbury), E. Sutton, and W. Farmer regarding G Club rule 2004 requests and confidentiality (.3); follow up call with W. Farmer, E. Sutton regarding same (.1) 0.40 1,625.00 650.00 07/05/2023 AEL2 Prepare notes for meet and confer with Y.

07/05/2023 AEL2 Meet and confer with counsel for Y. Almani

connection with rule 2004 requests (.4);

07/05/2023 AEL2 Analyze and summarize rule 2004 meetings with Y. Almani, G Club 1.20 1,625.00 1,950.00 07/05/2023 Prepare summary of information relating to

associates provided by informant 0.60 815.00 489.00 07/05/2023 NAB Email with A. Luft and L. Despins

counsel (.3); review U.S. Trustee response to same (.1); prepare parts of outline for M. Levine rule 2004 deposition (.7) 1.10 1,625.00 1,787.50

Date Initials Description Hours Rate Amount

07/05/2023 WCF Attend call with C. Fornos (GClub), E. Sutton, A. Luft regarding motion to compel compliance with Rule 2004 subpoena (.3); follow-up call with E. Sutton and A. Luft

HCHK Master Services agreement 1.00 1,235.00 1,235.00 regarding Rule 2004 data issues (.5);

07/06/2023 ECS1 Review information and update notes regarding Kwok affiliates and assets, their connections to Kwok, and related corporate

07/06/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.50 1,015.00 507.50 07/06/2023 ECS1 Prepare sixth supplemental omnibus rule 2004 motion (.4); correspond with D. Barron and A. Luft about same (.1) 0.50 1,015.00 507.50 07/06/2023 ECS1 Prepare responses to rule 2004 targets

07/06/2023 AEL2 Correspond with R. Connelly and N. Bassett re: ACASS rule 2004 information 0.40 1,625.00 650.00 07/06/2023 AEL2 Correspond with E. Sutton re: Cao rule

07/07/2023 DEB4 Correspond with A. Luft regarding forensic

07/07/2023 ECS1 Prepare topic outline for M. Levine Rule

07/07/2023 AEL2 Correspond with N. Bassett re: potential

07/07/2023 Review information related to Kwok's

07/07/2023 NAB Review key documents for M. Levine rule 2004 deposition (.3); email with E. Sutton regarding same (.1) 0.40 1,625.00 650.00 Case 22-50073r-D0d 2256 Filed 10/16/23-1 Entered 10/16/23 22:05:06 14Page 5214 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Date Initials Description Hours Rate Amount

07/08/2023 ECS1 Review and prepare documents for M. Levine Rule 2004 deposition 0.20 1,015.00 203.00 07/08/2023 NAB Review documents related to Hudson Diamond discovery dispute (.2); continue to

2004 deposition (.4) 0.60 1,625.00 975.00 07/09/2023 AEL2 Analyze supporting papers and exhibits re: Hudson Diamond motion 0.90 1,625.00 1,462.50 07/09/2023 AEL2 Analyze proposed RICO claim 0.40 1,625.00 650.00 07/09/2023 NAB Correspond with A. Luft regarding hearing

submissions relating to same (.4); prepare

deposition (1.2); email with E. Sutton and

same (.6); email with M. Levine regarding

07/10/2023 DEB4 Review and prepare documents for Hudson

07/10/2023 DEB4 Correspond with A. Luft regarding Hudson

withdraw as counsel 0.10 1,320.00 132.00 07/10/2023 DEB4 Conference with A. Luft regarding Hudson

withdraw as counsel 0.60 1,320.00 792.00 07/10/2023 DEB4 Conferences with E. Sutton regarding Hudson Diamond issues and Zeisler 0.40 1,320.00 528.00 Date Initials Description Hours Rate Amount 07/10/2023 ECS1 Prepare exhibits for M. Levine rule 2004

07/10/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.60 1,015.00 609.00 07/10/2023 AEL2 Call with D. Barron re: arguments related to Zeisler Hudson Diamond withdrawal 0.60 1,625.00 975.00 07/10/2023 AEL2 Correspond with N. Bassett re: Zeisler Hudson Diamond withdrawal arguments 0.20 1,625.00 325.00 07/10/2023 AEL2 Analyze submissions related to Zeisler Hudson Diamond motion to withdraw 0.50 1,625.00 812.50 07/10/2023 AEL2 Review underlying arguments and testimony

07/11/2023 DEB4 Correspond with P. Linsey (NPM) regarding Capital One production 0.30 1,320.00 396.00 07/11/2023 DEB4 Correspond with W. Farmer regarding M. Levine rule 2004 deposition 0.10 1,320.00 132.00 07/11/2023 DEB4 Correspond with A. Luft regarding Hudson Diamond transfers 0.40 1,320.00 528.00 07/11/2023 DEB4 Correspond with E. Sutton regarding M. Levine rule 2004 deposition 0.10 1,320.00 132.00 07/11/2023 ECS1 Analyze documents and related topics for M. Levine Rule 2004 deposition 1.30 1,015.00 1,319.50 07/11/2023 ECS1 Review and summarize documents produced in response to Rule 2004 requests 0.70 1,015.00 710.50 07/11/2023 ECS1 Prepare responses to rule 2004 targets

and meet and confers 0.30 1,015.00 304.50 07/11/2023 AEL2 Draft talking points re: Zeisler Hudson Diamond withdrawal motion for hearing 1.80 1,625.00 2,925.00 07/11/2023 AEL2 Analyze cases and arguments to prepare for

Date Initials Description Hours Rate Amount 07/11/2023 NAB Correspond with W. Farmer regarding

deposition and additional issues (.4); review

07/11/2023 WCF Analyze Philips Nizer and Elliot Kwok law firm documents regarding deposition of M.

2004 deposition (2.9) 7.20 1,235.00 8,892.00 07/12/2023 DEB4 Follow up correspondence with J. Voss (FRA) regarding investigation 0.20 1,320.00 264.00 07/12/2023 DEB4 Conference with J. Voss (FRA) and A. Luft regarding forensic accounting investigation 0.60 1,320.00 792.00 07/12/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.30 1,015.00 304.50 07/12/2023 ECS1 Analyze additional topics and related

07/12/2023 AEL2 Prepare outline for forensic accountant interview (.3); interview J. Voss with D. Barron re: forensic accounting assignment

07/12/2023 AEL2 Review report from N. Bassett re: Lamp Capital counsel deposition 0.10 1,625.00 162.50 07/12/2023 Review and summarize informant's email on Himalaya and Kwok's associates 0.50 815.00 407.50 07/12/2023 NAB Review and revise draft outline for M. Levine deposition (1.1); conference with W.

Date Initials Description Hours Rate Amount 07/12/2023 WCF Supplement outlines for Rule 2004

Levine law firm (1.6); conference with N. Bassett regarding same (.2); take Rule 2004

Levine law firm (2.5); follow up conference with N. Bassett regarding same (.3) 4.60 1,235.00 5,681.00 07/13/2023 DEB4 Analyze documents related to Kwok

07/13/2023 Review informant's email on HCHK and

07/14/2023 DEB4 Correspond with L Despins regarding

07/14/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.50 1,015.00 507.50 07/14/2023 ECS1 Prepare responses to rule 2004 targets

07/14/2023 ECS1 Prepare outline and cheat sheet in connection with Aaron Mitchell's testimony

and Saraca should not be held in contempt (2.0); correspond with A. Luft about same

07/14/2023 ECS1 Prepare documents and notes for 7/18/23

07/14/2023 Review documents on Relativity in

07/15/2023 AG30 Review F. Lawall and A. Mitchell

significant transfers or specific discussions 2.80 915.00 2,562.00 Date Initials Description Hours Rate Amount 07/15/2023 Review and summarize informant's email

companies and Kwok's associates 1.20 815.00 978.00 07/15/2023 Review production from Francis Lawall on

connection with GTV and Saraca 2.50 815.00 2,037.50 07/16/2023 AG30 Review documents from rule 2004

07/16/2023 ECS1 Prepare parts of outline in connection with

not be held in contempt 2.00 1,015.00 2,030.00 07/16/2023 Correspond with L. Despins on informant's email about Himalaya Farms 0.10 815.00 81.50 07/17/2023 DEB4 Correspond with E. Sutton regarding Hudson Diamond contempt order 0.10 1,320.00 132.00 07/17/2023 DEB4 Conference with A. Luft regarding A. Mitchell cross examination (2.1); prepare parts of outline for same (2.4) 4.50 1,320.00 5,940.00 07/17/2023 DEB4 Correspond with L. Despins regarding

07/17/2023 DEB4 Correspond with E. Sutton regarding ROLF 0.10 1,320.00 132.00 07/17/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.40 1,015.00 406.00 07/17/2023 ECS1 Continue to prepare outline in connection with Aaron Mitchell's testimony related to

should not be held in contempt (2.4); correspond with D. Barron about same (.5) 2.90 1,015.00 2,943.50 07/17/2023 ECS1 Review Rule of Law entities production of

summary of same for D. Barron (.2); correspond with P. Linsey (NPM) regarding 1.10 1,015.00 1,116.50 Date Initials Description Hours Rate Amount 07/17/2023 ECS1 Review and summarize documents produced in response to rule 2004 motions 1.10 1,015.00 1,116.50 07/17/2023 AEL2 Meet with D. Barron re: questioning of Aaron Mitchell re: GTV and Saraca (2.1); prepare part of cross examination for same

regarding same (.5) 2.90 1,625.00 4,712.50 07/17/2023 Review and summarize informant's email on farm activities and key Kwok associates 0.60 815.00 489.00 07/17/2023 Correspond with E. Sutton on exhibit list

07/17/2023 NAB Correspond with A. Luft regarding preparations for 7/18/23 hearing and A. Mitchell examination 0.20 1,625.00 325.00 07/18/2023 DEB4 Correspond with A. Luft regarding A. Mitchell documents 0.10 1,320.00 132.00 07/18/2023 ECS1 Prepare exhibits for hearing on order to

not be held in contempt in connection with the motion to compel 0.20 1,015.00 203.00 07/18/2023 ECS1 Discussions with UnitedLex about Kwok discovery database 0.30 1,015.00 304.50 07/18/2023 ECS1 Call with D. Barron regarding 7/18/23 hearing, discovery in adversary proceedings, and forensic accountant retention 0.30 1,015.00 304.50 07/18/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.60 1,015.00 609.00 07/18/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.90 1,015.00 913.50 07/18/2023 AEL2 Review and supplement cross examination outline for A. Mitchell 3.80 1,625.00 6,175.00 07/18/2023 AEL2 Call with N. Bassett re: A. Mitchell cross

07/18/2023 AEL2 Call with N. Bassett re: HCHK and A.

Date Initials Description Hours Rate Amount 07/18/2023 NAB Call with A. Luft regarding prep for hearing and cross examination of Aaron Mitchell in connection with discovery dispute (.4); call with A. Luft regarding HCHK and A. Mitchell hearing (.5); correspond with L. Despins regarding same (.1) 1.00 1,625.00 1,625.00 07/19/2023 DEB4 Correspond with N. Bassett regarding UAE

07/19/2023 DEB4 Correspond with P. Linsey (NPM) regarding EY discovery 0.10 1,320.00 132.00 07/19/2023 DEB4 Correspond with A. Bongartz regarding Kwok fee disclosure 0.10 1,320.00 132.00 07/19/2023 DEB4 Correspond with L. Despins regarding Kwok fee disclosures 0.10 1,320.00 132.00 07/19/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and related corporate information 0.50 1,015.00 507.50 07/19/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 1.30 1,015.00 1,319.50 07/19/2023 ECS1 Prepare document review protocol in

production (2.5); correspond with W.

about same (.3) 2.80 1,015.00 2,842.00 07/20/2023 ECS1 Prepare responses to rule 2004 targets in

requests and subpoenas (.1); call with P. Linsey (NPM) regarding same (.1) 0.20 1,015.00 203.00 07/20/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information (.1);

07/20/2023 ECS1 Call with Ross Fingold (counsel to Nodal

subpoena (.1); email Ross Fingold regarding

Date Initials Description Hours Rate Amount 07/20/2023 ECS1 Review and summarize documents

(.1); call with P. Linsey (NPM) about same

07/20/2023 ECS1 Prepare care package with and summarizing

Kwok discovery (.3); correspond with A. Ganapathi and J. Kuo about same (.3) 0.60 1,015.00 609.00 07/21/2023 ECS1 Review and summarize documents produced in response to rule 2004 request 0.10 1,015.00 101.50 07/21/2023 ECS1 Prepare responses to rule 2004 targets in

motions and subpoenas 0.10 1,015.00 101.50 07/21/2023 ECS1 Prepare care package with and summarizing

UnitedLex regarding same (.3) 0.40 1,015.00 406.00 07/21/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,015.00 203.00 07/21/2023 WCF Revise G-Club rule 2004 document review

07/22/2023 AEL2 Edit sixth supplemental rule 2004 motion 1.10 1,625.00 1,787.50 07/23/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.10 1,015.00 101.50 07/24/2023 DM26 Prepare parts of bank statements spreadsheet for forensic accountant 1.30 540.00 702.00 07/24/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.20 1,015.00 203.00 07/24/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.30 1,015.00 304.50 07/24/2023 ECS1 Prepare responses to rule 2004 targets

Date Initials Description Hours Rate Amount 07/24/2023 ECS1 Prepare care package with and summarizing

Kwok discovery (.2); correspond with A.

07/24/2023 AEL2 Correspond with D. Barron and E. Sutton

07/24/2023 Review information regarding certain

07/24/2023 Review informant's emails on Kwok related entities and persons 1.50 815.00 1,222.50 07/25/2023 DM26 Prepare parts of bank statements spreadsheet for forensic accountant 1.40 540.00 756.00 07/25/2023 DEB4 Correspond with regarding witness

07/25/2023 ECS1 Correspond with A. Ganapathi, , D.

07/25/2023 ECS1 Review and summarize documents produced in response to rule 2004 motion 0.10 1,015.00 101.50 07/25/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,015.00 203.00 07/25/2023 Prepare spreadsheet summary of bank

accounting analysis 4.00 815.00 3,260.00 07/26/2023 AG30 Prepare summary of bank account information for forensic analyst 3.50 915.00 3,202.50 07/26/2023 DEB4 Correspond with E. Sutton regarding next

07/26/2023 DEB4 Correspond with regarding update

07/26/2023 DEB4 Correspond with L. Despins regarding 0.20 1,320.00 264.00 Date Initials Description Hours Rate Amount 07/26/2023 DEB4 Analyze contempt decision 0.80 1,320.00 1,056.00 07/26/2023 DEB4 Correspond with S. Maza

07/26/2023 ECS1 Correspond with A. Ganapathi, , D.

07/26/2023 ECS1 Prepare sixth supplemental rule 2004

regarding same (.2) 1.40 1,015.00 1,421.00 07/26/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,015.00 203.00 07/26/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.30 1,015.00 304.50 07/26/2023 JK21 Prepare parts of forensic accountant bank

07/26/2023 LAD4 Read contempt ruling (.50); analyze/comment on RICO issues (2.90) 3.40 1,860.00 6,324.00 07/26/2023 Prepare parts of spreadsheet regarding bank statements for forensic analysis 3.00 815.00 2,445.00 07/26/2023 NAB Review debtor discovery contempt decision (.4); call with L. Despins regarding same (.2) 0.60 1,625.00 975.00

07/27/2023 ECS1 Prepare sixth supplemental rule 2004

regarding same (.2) 1.30 1,015.00 1,319.50 07/27/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.10 1,015.00 101.50 07/27/2023 ECS1 Correspond with A. Ganapathi, , D.

07/27/2023 JK21 Prepare parts of forensic accountant bank 2.00 540.00 1,080.00 Date Initials Description Hours Rate Amount 07/27/2023 Review information on Yaqin Li, witness

07/27/2023 Review G Club production for information

supplemental Rule 2004 motion 1.30 815.00 1,059.50 07/27/2023 NAB Review information related to witness who testified at protests preliminary injunction

developments related to same (.3); correspond with L. Despins regarding same

07/28/2023 DEB4 Correspond with N. Bassett regarding Kwok follower witness 0.20 1,320.00 264.00 07/28/2023 ECS1 Review document production and

accountant (3.4); correspond with D. Mohamed about same (.1) 3.50 1,015.00 3,552.50 07/28/2023 ECS1 Review and summarize documents produced in response to Rule 2004 requests 0.30 1,015.00 304.50 07/28/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.10 1,015.00 101.50 07/28/2023 ECS1 Prepare summary of certain financial transactions of the Debtor and his affiliates

rule 2004 discovery targets (.8); call with P. Linsey (NPM) regarding same (.2) 1.00 1,015.00 1,015.00 07/28/2023 Prepare summary of informant email on

07/28/2023 Review information on Yaqin Li, witness

07/28/2023 NAB Review order to show cause regarding Hudson Diamond discovery (.2); correspond with L. Despins regarding same

Date Initials Description Hours Rate Amount 07/30/2023 DM26 Prepare parts of bank statements spreadsheet for forensic accountant 2.50 540.00 1,350.00

informant emails (0.1); correspond with N. Bassett regarding potential disqualification of Yvette Wang's criminal counsel (0.1);

informant information (0.2) 0.40 1,320.00 528.00

informant emails (1.0); correspond with L.

formerfedsgroup.com (0.1) 1.10 1,320.00 1,452.00

07/31/2023 DEB4 Correspond with L. Despins regarding Kroll care package 0.10 1,320.00 132.00 07/31/2023 DEB4 Conference with E. Sutton regarding

07/31/2023 DEB4 Correspond with L. Despins regarding additional rule 2004 targets 0.20 1,320.00 264.00 07/31/2023 ECS1 Prepare response to Rule 2004 targets

07/31/2023 ECS1 Prepare chart and summary of bank

discovery for forensic accountant (3.3); call with D. Barron regarding same (.2);

07/31/2023 JK21 Prepare parts of bank statements spreadsheet for forensic accountant 4.40 540.00 2,376.00 07/31/2023 Review Nicole Tsai's July 29 livestream on

Subtotal: B261 Investigations 162.20 182,711.00

- 07/10/2023 DEB4 Conference with A. Luft regarding Hudson 07/10/2023 DEB4 Conferences with E. Sutton regarding motion to withdraw as counsel 07/10/2023 DEB4 Analyze Hudson Diamond/Zeisler withdrawal documents 0.80 1,320.00 1,056.00 07/10/2023 ECS1 Review and summarize transcripts in connection with Zeisler & Zeisler's motion to withdraw as counsel to Hudson Diamond NY (.9); prepare documents and hearing notes for 7/11/23 hearing 3.50 1,015.00 3,552.50 - regarding same (2.0); calls with D. Barron - about same (.4); correspond with D. Mohamed about same (.2) Case 22-50073r-D0d 2256 Filed 10/16/23-1 Entered 10/16/23 22:05:06 15Page 5215 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633 Case 22-50073r-D0d 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 1 Page 5226 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Date Initials Description Hours Rate Amount

07/24/2023 NAB Analyze arguments for Mei Guo discovery sanctions appeal (.4); call with P. Linsey (NPM), W. Farmer regarding same (.4) 0.80 1,625.00 1,300.00

WCF Call with P. Linsey (NPM), D. Carnelli and

contempt order appeal (.4); prepare notes regarding next steps (.1) 0.50 1,235.00 617.50 Subtotal: B262 Contempt Proceedings 1.30 1,917.50

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 3.90 1,860.00 7,254.00 NAB Nicholas A. Bassett Partner 15.20 1,625.00 24,700.00 NAB Nicholas A. Bassett Partner 2.90 812.50 2,356.25 AEL2 Luft, Avi E. Of Counsel 27.10 1,625.00 44,037.50 AEL2 Luft, Avi E. Of Counsel 2.30 812.50 1,868.75 AB21 Alex Bongartz Of Counsel 2.50 1,625.00 4,062.50 DEB4 Douglass E. Barron Associate 16.80 1,320.00 22,176.00

WCF Will C. Farmer Associate 15.80 1,235.00 19,513.00 ECS1 Ezra C. Sutton Associate 53.80 1,015.00 54,607.00 AG30 Anuva V. Ganapathi Associate 8.30 915.00 7,594.50

JK21 Jocelyn Kuo Paralegal 11.60 540.00 6,264.00 DM26 David Mohamed Paralegal 10.10 540.00 5,454.00

Case 22-50073r-D0d 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 1 Page 5227 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

Date Description Quantity Rate Amount

07/12/2023 Photocopy Charges 552.00 0.08 44.16 07/18/2023 Photocopy Charges 714.00 0.08 57.12 07/01/2023 Electronic Document Retrieval - TransUnion Risk and Alternative Data Solutions, Inc., Invoice# 1047352-202306-1 Dated 07/01/23, TLO Charges for June 01, 2023 - June 30, 2023 - TruLookup US

07/03/2023 Computer Search (Other) 1.08 07/04/2023 Computer Search (Other) 1.08 07/05/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163273; 07/05/2023; ; NA; 1 WORLD TRADE CTR; NEW YORK, NY 10007 ;

07/05/2023 Computer Search (Other) 1.08 07/06/2023 Airfare - Nick Bassett; 06/26/2023; From/To: DCA/LGA; Airfare Class: Economy; Travel to

07/06/2023 Travel Expense - Meals - Nick Bassett; 06/26/2023; Restaurant: Big Bowl; City: Arlington, VA; Lunch; Number of people: 1; Travel to NY/CT to meet

Case 22-50073r-D0d 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 1 Page 5228 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 23

07/06/2023 Travel Expense - Meals - Nick Bassett; 06/27/2023; Restaurant: Spotted Horse Tavern; City: Shelton, CT; Dinner; Number of people: 1; Travel to

07/06/2023 Lodging - Nick Bassett; 06/28/2023; Hotel: Marriott; City: Shelton, CT; Check-in date: 06/26/2023; Check-out date: 06/28/2023; Travel to

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/27/2023; From/To: meeting/hotel; Service Type: Uber; Time: 17:12; Travel to NY/CT to meet

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/27/2023; From/To: hotel/dinner; Service Type: Uber; Time: 18:26; Travel to NY/CT to meet with

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/27/2023; From/To: hotel/meeting; Service Type: Uber; Time: 09:38; Travel to NY/CT to meet

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/27/2023; From/To: dinner/hotel; Service Type: Uber; Time: 21:03; Travel to NY/CT to meet with

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/28/2023; From/To: hotel/meeting; Service Type: Uber; Time: 08:11; Travel to NY/CT to meet

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/26/2023; From/To: home/airport; Service Type: Uber; Time: 18:41; Travel to NY/CT to meet

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/26/2023; From/To: airport/hotel; Service Type: Uber; Time: 21:15; Travel to NY/CT to meet with

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/28/2023; From/To: office/meeting; Service Type: Uber; Time: 12:47; Travel to NY/CT to meet

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/28/2023; Travel to NY/CT to meet with client-

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/28/2023; Travel to NY/CT to meet with client-

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/28/2023; Rail: Amtrak; Travel to NY/CT to

07/06/2023 Taxi/Ground Transportation - Nick Bassett; 06/28/2023; From/To: train station/home; Service Type: Uber; Time: 16:03; Travel to NY/CT to meet

07/06/2023 Local - Meals - Nick Bassett; 06/28/2023; Restaurant: Birch Coffee; City: New York; Coffee; Number of people: 1; Travel to NY/CT to meet

07/06/2023 Vendor Expense - Nick Bassett; 06/26/2023; Travel to NY/CT to meet with client; Baggage Fee 35.00

07/11/2023 Computer Search (Other) 0.18 07/11/2023 Computer Search (Other) 2.61 07/12/2023 Computer Search (Other) 2.70 07/13/2023 Computer Search (Other) 2.61 07/14/2023 Computer Search (Other) 0.90 07/17/2023 Computer Search (Other) 0.72

07/18/2023 Computer Search (Other) 0.90 07/19/2023 Airfare - Nick Bassett; 07/10/2023; From/To: DCA/LGA; Airfare Class: Economy; Travel to NY/CT to meet with client (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included

07/19/2023 Travel Expense - Meals - Nick Bassett; 07/11/2023; Restaurant: Mystik Masala; City: New York; Dinner; Number of people: 1; Travel to NY/CT to meet with client (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included both matters) 12.37 07/19/2023 Travel Expense - Meals - Nick Bassett; 07/11/2023; Restaurant: Lebanese Taverna Express; City: New York; Lunch; Number of people: 1; Travel to NY/CT to meet with client (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included

07/19/2023 Travel Expense - Meals - Nick Bassett; 07/12/2023; Restaurant: LGA Hunt and Fish Club; City: New York; Lunch; Number of people: 1; Travel to NY/CT to meet with client (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included

07/19/2023 Lodging - Nick Bassett; 07/12/2023; Hotel: Hyatt; City: New York; Check-in date: 07/11/2023; Check out date: 07/12/2023; Travel to NY/CT to meet with client (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included both matters) 230.67 07/19/2023 Taxi/Ground Transportation - Nick Bassett; 07/11/2023; From/To: home/DCA; Service Type: Uber; Time: 06:45; Travel to NY/CT to meet with client (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included both matters) 10.00 07/19/2023 Taxi/Ground Transportation - Nick Bassett; 07/12/2023; From/To: DCA/Home; Service Type: Uber; Time: 19:24; Travel to NY/CT to meet with client (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included both matters) 10.45 07/19/2023 Taxi/Ground Transportation - Nick Bassett; 07/11/2023; From/To: LGA/Meeting in CT; Service Type: Uber; Time: 09:25; Travel to NY/CT to meet with client (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included both

07/19/2023 Taxi/Ground Transportation - Nick Bassett; 07/12/2023; From/To: PH/LGA; Service Type: Uber; Time: 14:15; Travel to NY/CT to meet with client (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included both matters) 38.49 07/19/2023 Travel Expense - Internet - Nick Bassett; 07/11/2023; Travel to NY/CT to meet with client; Inflight Wi-Fi (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included both

07/19/2023 Travel Expense - Internet - Nick Bassett; 07/11/2023; Travel to NY/CT to meet with client; Inflight Wi-Fi (Bill 1/2 to Matter 2 and 1/2 to Matter 15 as purpose of travel included both

Case 22-50073r-D0d 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 1 Page 5229 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2369633

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan

07/26/2023 Local - Taxi - Douglass Barron; 07/18/2023; From/To: Office/Home ; Service Type: Lyft; Time: 02:37; working late on Kwok matter 33.74

07/26/2023 Attorney Service - Serving By Irving Inc., Invoice# YL-4015A Dated 07/26/23, two services of First Set of Requests on Anthony DiBattista and Brian Hofmeister and the attempted service and service of a subpoena on Linwan "Irene" Feng 575.00

07/28/2023 Local - Meals - Douglass Barron; 07/18/2023; Restaurant: Han Dynasty; City: New York ; Dinner; Number of people: 1; Working late on Kwok matter 34.29 07/28/2023 Local - Parking - Luc Despins; 06/27/2023; Parking

07/28/2023 Local - Parking - Luc Despins; 05/30/2023; Parking

07/31/2023 Airfare - Will Farmer; 07/10/2023; From/To: LAX/JFK/JFK/LAX; Airfare Class: Economy; Travel to and from NYC for a deposition; Delta

07/31/2023 Lodging - Will Farmer; 07/13/2023; Hotel: Hampton Inn; City: New York; Check-in date: 07/11/2023; Check-out date: 07/13/2023; Travel to

07/31/2023 Taxi/Ground Transportation - Will Farmer; 07/14/2023; From/To: hotel/airport; Service Type: Taxi; Time: 14:00; Travel to and from NYC for a

07/31/2023 Taxi/Ground Transportation - Will Farmer; 07/11/2023; From/To: airport/hotel; Service Type: Taxi; Time: 14:00; Travel to and from NYC for a

07/31/2023 Travel Expense - Parking - Will Farmer;

deposition; LAX Smartparking - Parking at LAX for Tuesday - Thursday 7/11/23 – 7/13/23 104.99 Case 22-50073r-D0c12256 Filed 10/16/23-1Entered 10/16/23 22:05:06 16Page 5233 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 28

07/31/2023 Travel Expense - Parking - Will Farmer;

07/31/2023 UnitedLex Invoices - Unitedlex Corp, Invoice# 088560 Dated 07/31/23, UnitedLex – DSAI July 2023 Charges – Outside Professional Services 93,448.02 07/31/2023 Vendor Expense - Will Farmer; 07/14/2023; Travel to and from NYC for a deposition; Delta Airlines - Additional Delta flight change fee; Service Charge 10.00 07/31/2023 Vendor Expense - Will Farmer; 07/13/2023; Travel to and from NYC for a deposition; Delta Airlines –

Total Costs incurred and advanced \$101,630.32

Total Balance Due - Due Upon Receipt \$320,751.82 Case 22-50073r-D0c12256 Filed 10/16/23-1Entered 10/16/23 22:05:06 16Page 5234 of 486

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Other Litigation PH LLP Client/Matter # 50687-00003 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$2,431.00

Total Balance Due - Due Upon Receipt \$3,386.62

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address: Paul Hastings LLP Lockbox 4803 PO Box 894803 Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-D0c12256 Filed 10/16/23-1Entered 10/16/23 22:05:06 17Page 5235 of 486

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Other Litigation PH LLP Client/Matter # 50687-00003 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$2,431.00

Total Balance Due - Due Upon Receipt \$3,386.62

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-D0d 2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 17Page 5236 of 486

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023

New York, NY 10166 Invoice Number: 2369634

Attn: Luc Despins PH LLP Tax ID No. 95-2209675 FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2023

Date Initials Description Hours Rate Amount

07/03/2023 JK21 Correspond with L. Despins regarding Kwok criminal proceedings 0.30 540.00 162.00 07/05/2023 JK21 Correspond with L. Despins regarding Kwok criminal proceedings 0.20 540.00 108.00 07/06/2023 JK21 Correspond with L. Despins regarding Kwok criminal proceedings 0.20 540.00 108.00 07/11/2023 JK21 Review Kwok criminal case and appeals for newly filed pleadings for L. Despins 0.20 540.00 108.00 07/12/2023 JK21 Review Kwok criminal case and appeals for newly filed pleadings for L. Despins (0.2);

Kwok criminal case (0.2) 0.40 540.00 216.00 07/13/2023 JK21 Review Kwok criminal case and appeals for newly filed pleadings for L. Despins (0.2);

Kwok criminal case (0.2) 0.40 540.00 216.00 07/15/2023 NAB Review decision from criminal court on

Case 22-50073r-D0d 2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 17Page 5237 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2369634

Date Initials Description Hours Rate Amount

07/17/2023 JK21 Review recent filings in Kwok criminal case and appeals (0.2); correspond with L. Despins regarding Kwok criminal case (0.2) 0.40 540.00 216.00 07/18/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.20 540.00 108.00 07/19/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.20 540.00 108.00 07/20/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.20 540.00 108.00 07/21/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.20 540.00 108.00 07/24/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.20 540.00 108.00 07/25/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.20 540.00 108.00 07/26/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.20 540.00 108.00 07/28/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.20 540.00 108.00 07/31/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.20 540.00 108.00 Subtotal: B191 General Litigation 4.10 2,431.00

ID Timekeeper Name Title Hours Rate Fee

NAB Nicholas A. Bassett Partner 0.20 1,625.00 325.00 JK21 Jocelyn Kuo Paralegal 3.90 540.00 2,106.00 Case 22-50073r-D0d 2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 17Page 5238 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2369634 Page 3

Date Description Quantity Rate Amount

07/06/2023 Computer Search (Other) 7.20

Total Costs incurred and advanced \$955.62

Total Balance Due - Due Upon Receipt \$3,386.62 Case 22-50073r-D0d 2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 17Page 5239 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Corporate Law Issues PH LLP Client/Matter # 50687-00004 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$12,843.50

Total Balance Due - Due Upon Receipt \$12,843.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-D0d 2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 17Page 5240 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Corporate Law Issues PH LLP Client/Matter # 50687-00004 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$12,843.50

Total Balance Due - Due Upon Receipt \$12,843.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-D0d 2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 17Page 5241 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023

New York, NY 10166 Invoice Number: 2369635

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2023

Date Initials Description Hours Rate Amount

B190 Other Contested Matters(excl. assumption/rejections motions) 07/06/2023 NAB Email with E. Henzy (Zeisler) and P. Linsey

07/09/2023 NAB Email with P. Linsey (NPM) regarding Ace Decade contempt appeal 0.10 1,625.00 162.50 07/20/2023 NAB Correspond with E. Henzy (Zeisler) regarding Ace Decade contempt appeal 0.20 1,625.00 325.00 07/25/2023 AB21 Revise status report for appeal of corporate governance order (0.4); correspond with L.

with J. Moriarty (Zeisler) regarding same (0.1); call with J. Moriarty regarding same

07/25/2023 LAD4 Numerous emails with J. Moriarty (Z&Z) re: appeal status report re: letter ruling 1.20 1,860.00 2,232.00 07/26/2023 AB21 Correspond with L. Despins and N. Bassett regarding joint status report for corporate governance order appeal (0.2); call with N. Bassett regarding same (0.1); analyze same

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00004 Invoice No. 2369635

Date Initials Description Hours Rate Amount

07/26/2023 LAD4 Mark-up final draft appeal report 0.30 1,860.00 558.00 07/26/2023 NAB Correspond with L. Despins and A.

issues and strategy (.1); call with A. Bongartz regarding same (.1) 0.20 1,625.00 325.00 07/27/2023 AB21 Call with L. Despins and N. Bassett

corporate governance order (0.3);

regarding same (0.1) 0.40 1,625.00 650.00 07/27/2023 LAD4 T/c A. Bongartz & N. Bassett re: delay in Ace Decade contempt appeal 0.30 1,860.00 558.00 07/27/2023 NAB Call with L. Despins and A. Bongartz

strategy (.3); analyze issues related to same

07/28/2023 AB21 Finalize joint status report for appeal of corporate governance order (0.1); correspond with N. Bassett regarding same (0.1); correspond with J. Moriarty (Zeisler) regarding same (0.1) 0.30 1,625.00 487.50 Subtotal: B190 Other Contested Matters(excl. assumption/rejections motions) 4.80 8,223.00

07/17/2023 AB21 Call with A. Thorp (Harneys Legal) regarding Ace Decade strategy 0.10 1,625.00 162.50

07/18/2023 AB21 Correspond with A. Thorp (Harneys Legal)

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00004 Invoice No. 2369635

Date Initials Description Hours Rate Amount

07/19/2023 AB21 Call with A. Thorp (Harneys Legal) regarding BVI strategy with respect to Ace Decade (0.4); analyze same (0.3);

(0.1); correspond with N. Bassett, A. Luft and L. Despins regarding same (0.2); call with A. Luft and L. Despins regarding same (0.2); further call with L. Despins regarding

regarding same (0.3) 1.60 1,625.00 2,600.00 07/19/2023 LAD4 T/c A. Bongartz, A. Luft re: Ace Decade next steps (.20); t/c A. Bongartz re: BVI

07/19/2023 AEL2 Call with A. Bongartz and L. Despins re: BVI legal question re: Ace Decade 0.20 1,625.00 325.00 Subtotal: B191 General Litigation 2.80 4,620.50

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 2.10 1,860.00 3,906.00 NAB Nicholas A. Bassett Partner 1.20 1,625.00 1,950.00 AB21 Alex Bongartz Of Counsel 4.10 1,625.00 6,662.50 AEL2 Luft, Avi E. Of Counsel 0.20 1,625.00 325.00

Total Balance Due - Due Upon Receipt \$12,843.50

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Sales Process PH LLP Client/Matter # 50687-00005 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$7,875.50

Total Balance Due - Due Upon Receipt \$11,707.25

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Sales Process PH LLP Client/Matter # 50687-00005 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$7,875.50

Total Balance Due - Due Upon Receipt \$11,707.25

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023

New York, NY 10166 Invoice Number: 2369636

Attn: Luc Despins PH LLP Tax ID No. 95-2209675 FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2023

Date Initials Description Hours Rate Amount

07/05/2023 AB21 Correspond with D. Johnson (Edmiston) regarding update on Lady May 2 0.10 1,625.00 162.50 07/05/2023 DEB4 Correspond with L. Despins regarding objections to Lady May sale 0.10 1,320.00 132.00 07/05/2023 ECS1 Prepare closing statement and notice thereof in connection with sale of the Lady

07/06/2023 AB21 Correspond with R. Stockil (Yachtzoo)

notice of closing statement (0.2); call and

07/06/2023 ECS1 Prepare closing statement and notice thereof in connection with sale of the Lady May (.5); call and correspond with A. Bongartz about same (.1) 0.60 1,015.00 609.00

Date Initials Description Hours Rate Amount

07/07/2023 AB21 Finalize closing statement for Lady May sale (0.1); correspond with L. Despins regarding

(Neubert) regarding same (0.1); correspond with E. Sutton and J. Kuo regarding filing and service of same (0.1) 0.40 1,625.00 650.00 07/07/2023 ECS1 Prepare closing statement in connection with the sale of the Lady May 0.70 1,015.00 710.50 07/07/2023 JK21 Prepare closing statement regarding Lady May sale (0.2); electronically file with the court closing statement regarding Lady May

07/10/2023 AB21 Call with L. Macdonald (Alley Maass) regarding crew salary payment (0.3); correspond with R. Stockil (Yachtzoo) and J. Avedis (Yachtzoo) regarding same (0.2); call with D. Johnson (Edmiston) regarding Lady May 2 sale process (0.2) 0.70 1,625.00 1,137.50 07/11/2023 AB21 Review correspondence from J. Avedis

07/13/2023 AB21 Correspond with R. Stockil (Yachtzoo) regarding crew releases 0.10 1,625.00 162.50 07/14/2023 AB21 Correspond with D. Johnson (Edmiston) regarding delivery of storage pod 0.10 1,625.00 162.50 07/17/2023 AB21 Correspond with D. Johnson (Edmiston) regarding storage pod (0.2); call with D. Johnson regarding same (0.2); call with L.

releases (0.1); correspond with L. Macdonald regarding same (0.1) 0.60 1,625.00 975.00 07/19/2023 AB21 Call with D. Johnson (Edmiston) regarding update on Lady May 2 sale process (0.1); review customs bond application (0.2);

Maass) regarding crew releases with respect to Lady May sale (0.1) 0.40 1,625.00 650.00 Case 22-50073r-00d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 18Page 5248 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00005 Invoice No. 2369636

Date Initials Description Hours Rate Amount

07/20/2023 AB21 Call with E. Sutton regarding motion to authorize auctioning of Sherry Netherland

07/20/2023 ECS1 Call with A. Bongartz regarding motion to auction estate assets (.1); call with P. Linsey (NPM) regarding same (.1) 0.20 1,015.00 203.00 07/21/2023 ECS1 Review correspondence from P. Linsey

07/23/2023 ECS1 Review correspondence from P. Linsey

07/24/2023 AB21 Correspond with D. Johnson (Edmiston)

07/24/2023 ECS1 Correspond with A. Bongartz and P. Linsey

Subtotal: B130 Asset Disposition 6.10 7,875.50

ID Timekeeper Name Title Hours Rate Fee

AB21 Alex Bongartz Of Counsel 3.10 1,625.00 5,037.50 DEB4 Douglass E. Barron Associate 0.10 1,320.00 132.00 ECS1 Ezra C. Sutton Associate 2.40 1,015.00 2,436.00 JK21 Jocelyn Kuo Paralegal 0.50 540.00 270.00 Case 22-50073r-00d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 18Page 5249 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00005 Invoice No. 2369636 Page 4

Date Description Quantity Rate Amount

07/03/2023 Outside Professional Services - Bohonnon Law

Professional services rendered - June 2023 3,831.75 Total Costs incurred and advanced \$3,831.75

Total Balance Due - Due Upon Receipt \$11,707.25 Case 22-50073r-00d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 18Page 5250 of 486

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever US PH LLP Client/Matter # 50687-00010 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$33,189.75

Total Balance Due - Due Upon Receipt \$33,189.75

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-00d2256 Filed 10/16/23-1Entered 10/2/6/23 22:05:06 18Page 5251 of 486

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever US PH LLP Client/Matter # 50687-00010 Nicholas A. Bassett

Legal fees for professional services for the period ending July 31, 2023 \$33,189.75

Total Balance Due - Due Upon Receipt \$33,189.75

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023

New York, NY 10166 Invoice Number: 2369637

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2023

Date Initials Description Hours Rate Amount

07/05/2023 AB21 Correspond with L. Despins regarding

Corporate) with respect to Genever US 0.10 1,625.00 162.50 07/20/2023 AB21 Correspond with C. Abrehart (Genever

07/21/2023 AB21 Call with G. Weston (Harneys Legal) regarding power of attorney with respect to

07/21/2023 AB21 Correspond with C. Abrehart (Genever BVI director) regarding case update call 0.10 1,625.00 162.50 07/23/2023 AB21 Correspond with L. Despins regarding update call with C. Abrehart (director) 0.40 1,625.00 650.00 07/24/2023 AB21 Call with C. Abrehart (Genever BVI

and DIP financing 0.40 1,625.00 650.00 Date Initials Description Hours Rate Amount 07/26/2023 AB21 Correspond with C. Abrehart (Genever

Subtotal: B110 Case Administration 1.40 2,275.00

07/19/2023 LAD4 Review/comment on sale process Sherry

Subtotal: B131 Sale of Real Estate 3.10 5,766.00 B165 Fee/Employment Applications for Other Professionals 07/07/2023 AB21 Correspond with L. Despins regarding

AAGL retention application (0.2);

regarding same (0.1) 0.30 1,625.00 487.50 07/08/2023 AB21 Correspond with L. Despins regarding AAGL retention application (0.2); correspond with H. Claiborn (U.S. Trustee) regarding same (0.1) 0.30 1,625.00 487.50 07/10/2023 AB21 Revise proposed order for AAGL retention (0.3); correspond with H. Claiborn (U.S. Trustee) regarding same (0.1); correspond with J. Kuo regarding notice of filing of

07/20/2023 AB21 Research regarding potential insurance counsel (1.8); correspond with L. Despins regarding same (0.1) 1.90 1,625.00 3,087.50 07/21/2023 AB21 Research regarding potential insurance counsel (1.2); correspond with L. Despins regarding same (1.1) 2.30 1,625.00 3,737.50 Date Initials Description Hours Rate Amount 07/24/2023 AB21 Call with P. Linsey regarding retention of architect (0.1); correspond with L. Despins regarding same (0.2); correspond with H. Claiborn (U.S. Trustee) regarding same (0.2) 0.50 1,625.00 812.50 07/25/2023 AB21 Correspond with P. Linsey (Neubert) regarding retention of architect 0.10 1,625.00 162.50 07/27/2023 AB21 Correspond with D. Acheson (architect) regarding retention application (0.2);

McCormick retention application (0.2) 0.40 1,625.00 650.00 07/31/2023 AB21 Correspond L. Despins regarding OMJB retention application (0.2); revise same (0.2);

regarding same (0.1); correspond with D.

(Neubert) regarding same (0.2) 0.80 1,625.00 1,300.00 Subtotal: B165 Fee/Employment Applications for

07/20/2023 AB21 Non-working travel to/from NY office to Sherry Netherland apartment (Bill at 1/2 rate) 0.70 812.50 568.75 07/27/2023 AB21 Travel from PH office to SN apartment for site visit with architect (Bill at 1/2 rate) 0.60 812.50 487.50 07/12/2023 DEB4 Correspond with L. Despins regarding discussion with Wolfson agency 0.20 1,320.00 264.00 07/14/2023 DEB4 Conference with T. Sadler regarding Genever insurance 0.10 1,320.00 132.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2369637 Page 2

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2369637

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2369637

07/27/2023 AB21 Site visit of SN apartment with D. Acheson

(architect) (0.8); correspond with L. Despins

Subtotal: B210 Business Operations 7.40 12,423.00

Date Initials Description Hours Rate Amount

07/14/2023 DEB4 Correspond with L. Despins regarding Genever insurance 0.20 1,320.00 264.00 07/14/2023 TS21 Call with D. Barron re AIG insurance

comment on AIG insurance payments (.3) 0.50 1,175.00 587.50 07/20/2023 AB21 Correspond with K. Catalano regarding

Netherland apartment 0.20 1,625.00 325.00 07/20/2023 AB21 Meeting with L. Despins, M. Ullman

07/20/2023 LAD4 Visit SN apartment with A. Bongartz and J. Panico (public adjuster) 1.00 1,860.00 1,860.00 07/25/2023 AB21 Call with D. Acheson (architect) regarding

apartment (0.4); correspond with D.

with L. Despins regarding same (0.1) 0.60 1,625.00 975.00 07/25/2023 LAD4 T/c J. Panico (adjuster) re: repairs

on same (architect/contractor) (1.40) 2.30 1,860.00 4,278.00 07/26/2023 AB21 Correspond with D. Acheson (architect) regarding Sherry Netherland site visit (0.1); correspond with L. Despins regarding same

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2369637

Date Initials Description Hours Rate Amount

B211 Financial Reports (Monthly Operating Reports)

Correspond with D. Skalka (NPM) and J. Gervais (UST) regarding MOR 0.10 1,320.00 132.00 Subtotal: B211 Financial Reports (Monthly

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 6.40 1,860.00 11,904.00 AB21 Alex Bongartz Of Counsel 11.60 1,625.00 18,850.00 AB21 Alex Bongartz Of Counsel 1.30 812.50 1,056.25 DEB4 Douglass E. Barron Associate 0.60 1,320.00 792.00 TS21 Tess Sadler Associate 0.50 1,175.00 587.50

Total Balance Due - Due Upon Receipt \$33,189.75

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Mahwah Adversary Proceeding PH LLP Client/Matter # 50687-00012

Legal fees for professional services for the period ending July 31, 2023 \$98,916.00

Total Balance Due - Due Upon Receipt \$99,266.90

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5258 of

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00012 Luc A. Despins

Legal fees for professional services for the period ending July 31, 2023 \$98,916.00

Total Balance Due - Due Upon Receipt \$99,266.90

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:\nPaul Hastings LLP\nLockbox 4803\nPO Box 894803\nLos Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5259 of

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023

New York, NY 10166 Invoice Number: 2369638

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2023

Date Initials Description Hours Rate Amount

07/02/2023 Analyze Bankruptcy Code section 542 on turning over real estate to the trustee 0.60 815.00 489.00 07/02/2023 NAB Correspond with L. Despins and S. Maza

order, and DOJ stipulation issues (.2); analyze same (.4) 0.60 1,625.00 975.00 07/02/2023 SM29 Revise TRO motion and order to incorporate L. Despins comments (.4); correspond with N. Bassett re same (.2); analyze authority re same (.4) 1.00 1,320.00 1,320.00 07/03/2023 DEB4 Correspond with I. Goldman (Pullman) regarding DOJ stipulation 0.10 1,320.00 132.00 07/03/2023 DEB4 Correspond with S. Maza regarding Taurus

07/03/2023 DEB4 Correspond with S. Maza regarding

07/03/2023 DEB4 Correspond with S. Sarnoff regarding DOJ

Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5260 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2369638

Date Initials Description Hours Rate Amount 07/03/2023 DEB4 Correspond with L. Despins regarding DOJ stipulation 0.10 1,320.00 132.00 07/03/2023 DEB4 Conference with regarding Bankruptcy Rule 7070 0.10 1,320.00 132.00 07/03/2023 DEB4 Correspond with J. Murray (DOJ) regarding DOJ stipulation 0.10 1,320.00 132.00 07/03/2023 DEB4 Conference with L. Despins and J. Murray (DOJ) regarding DOJ stipulation 0.20 1,320.00 264.00 07/03/2023 DEB4 Revise DOJ stipulation 0.40 1,320.00 528.00 07/03/2023 DEB4 Correspond with regarding Bankruptcy Rule 7070 0.10 1,320.00 132.00 07/03/2023 JK21 Research regarding Bankruptcy Code section 542 and Rule 7070 orders 0.80 540.00 432.00 07/03/2023 JK21 Review and revise Mahwah complaint 2.30 540.00 1,242.00 07/03/2023 JK21 Research regarding turnover orders for S. Maza 1.80 540.00 972.00 07/03/2023 LAD4 Review/edit DOJ stip (1.10); t/c J. Murray (DOJ) & D. Barron re: same (.20) 1.30 1,860.00 2,418.00 07/03/2023 Correspond with J. Kuo on filing preparation 0.10 815.00 81.50 07/03/2023 Conference with D. Barron regarding Bankruptcy Rule 7070 (.1); prepare memorandum on the scope and application of Bankruptcy Rule 7070 in relation to the 1.90 815.00 1,548.50

of Bankruptcy Rule 7070 in relation to the

07/03/2023 Correspond with D. Barron on Bankruptcy

07/03/2023 SM29 Analyze case law and precedent re TROs (1.6); correspond with L. Despins re same (.4); revise same (.3) 2.30 1,320.00 3,036.00 07/05/2023 LAD4 Review/edit revised docs (1.70); t/c S. Maza re: same (.40) 2.10 1,860.00 3,906.00 07/05/2023 AEL2 Prepare comments on draft Mahwah

Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5261 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2369638

Date Initials Description Hours Rate Amount

07/05/2023 Review and revise the Mahwah adversary

07/05/2023 SM29 Call with L. Despins re TRO and Mahwah

07/06/2023 DEB4 Correspond with regarding DOJ

07/06/2023 DEB4 Correspond with S. Maza regarding Mahwah adversary proceeding filings 0.20 1,320.00 264.00 07/06/2023 JK21 Prepare exhibits to Mahwah complaint 1.20 540.00 648.00 07/06/2023 LAD4 Review/comment on exhibits to pleadings (1.30); t/c J. Iverson (USMS) re: TRO terms (.40); t/c S. Maza re: same (.20) 1.90 1,860.00 3,534.00 07/06/2023 Prepare NFSC videos cited in the Mahwah mansion complaint as exhibits 5.90 815.00 4,808.50 07/06/2023 Calls with S. Maza on the Mahwah adversary pleadings and evidentiary matters 0.30 815.00 244.50 07/06/2023 Revise exhibit list for the Mahwah

07/06/2023 Review pictures of the Mahwah mansion shared by law enforcement 0.30 815.00 244.50 07/06/2023 NAB Call with S. Maza regarding Mahwah complaint and TRO papers (.3); correspond with S. Maza regarding same (.3); analyze issues related to same (.3); call with F. Lawall (Troutman) regarding same (.3);

regarding same and related issues (.6); review case law relating to same (.3); correspond with L. Despins regarding same 2.30 1,625.00 3,737.50

Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5262 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2369638

Date Initials Description Hours Rate Amount

07/06/2023 SM29 Call with N. Bassett re video evidence for Mahwah complaint (.3); calls with re same (.3); correspond with regarding same and Mahwah pleadings (.2);

complaint (.3); review and prepare parts of

(6.4); call with L. Despins re same (.2) 7.70 1,320.00 10,164.00

07/07/2023 DEB4 Correspond with L. Despins regarding DOJ

Mahwah adversary proceeding complaint 0.20 1,015.00 203.00 07/07/2023 JK21 Prepare exhibits to the Mahwah complaint 2.80 540.00 1,512.00 07/07/2023 Continue to prepare exhibits and video exhibits for the Mahwah complaint 0.70 815.00 570.50 07/07/2023 NAB Review and revise draft Mahwah litigation

regarding same (.3) 0.90 1,625.00 1,462.50 07/07/2023 SM29 Review and revise Mahwah complaint and related pleadings (3.8); analyze evidentiary

07/08/2023 DEB4 Correspond with S. Maza regarding Mahwah issues (0.1); correspond with L. Despins re: same (0.1) 0.20 1,320.00 264.00 07/09/2023 Review and revise pleadings for the Mahwah adversary proceeding 1.90 815.00 1,548.50 07/10/2023 DEB4 Conference with S. Maza regarding Mahwah adversary proceeding theories 0.30 1,320.00 396.00 07/10/2023 DEB4 Correspond with N. Bassett regarding call

07/10/2023 Review and revise the Mahwah TRO

Date Initials Description Hours Rate Amount 07/10/2023 SM29 Call with D. Barron re alter ego issues and

comments (.1); revise same (.2) 0.60 1,320.00 792.00

07/11/2023 DEB4 Conference with S. Maza and J. Kuo regarding Mahwah complaint issue 0.30 1,320.00 396.00 07/11/2023 DEB4 Conference with J. Murray (DOJ), S. Maza

07/11/2023 DEB4 Conference with S. Maza regarding

evidentiary issues (.1); analyze evidentiary issues and privilege related to same (.6) 0.70 1,320.00 924.00 07/11/2023 ECS1 Correspond with J. Kuo and P. Linsey

adversary proceeding complaint 0.20 1,015.00 203.00 07/11/2023 JK21 Prepare pleadings and exhibits for filing Mahwah complaint under seal (3.4); telephone conference with S. Maza and D.

related pleadings (0.3) 3.70 540.00 1,998.00 07/11/2023 LAD4 T/c J. Tyminski (USMS) re: next steps (.30);

with J. Murray re: stipulation (.10) 0.80 1,860.00 1,488.00 07/11/2023 Review and revise Mahwah complaint and

07/11/2023 SM29 Call with L. Despins, D. Barron and DOJ re Mahwah complaint (.4); correspond with L. Despins re same (.1); review open issues to prepare for same (.2); correspond with N. Bassett re evidentiary issues and privilege in 1.40 1,320.00 1,848.00 Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5263 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2369638

connection with Mahwah complaint (.2); call with D. Barron re same (.1); call with J.

Kuo and D. Barron re same (.3); correspond with L. Despins re filing

Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5264 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2369638

Date Initials Description Hours Rate Amount

07/12/2023 DEB4 Correspond with S. Maza regarding

07/12/2023 DEB4 Revise DOJ stipulation (0.3); correspond with J. Murray (DOJ) regarding same (0.1) 0.40 1,320.00 528.00 07/12/2023 DEB4 Correspond with L. Despins regarding DOJ

07/12/2023 ECS1 Correspond with S. Maza and

07/12/2023 ECS1 Prepare amended exhibits and notice

(1.8); correspond with S. Maza about same

07/12/2023 AEL2 Review appearance filing 0.10 1,625.00 162.50 07/12/2023 NAB Correspond with W. Farmer and L. Despins regarding Mahwah litigation issues 0.20 1,625.00 325.00 07/12/2023 SM29 Call Clerk's office re docket and certain exhibits (.2); correspond with Clerk re same (.2); review docket and exhibits (.5);

counsel) and E. Sutton re filing same (.2); correspond with A. Bongartz re same (.1); correspond with L. Despins re same (.1) 1.90 1,320.00 2,508.00 07/13/2023 AB21 Correspond with L. Despins regarding security at Mahwah property 0.10 1,625.00 162.50 07/13/2023 LAD4 Meeting W. Farmer re: Mahwah take over (.50); t/c S. Batista (guidepost) re: security at Mahwah (.30) 0.80 1,860.00 1,488.00 07/13/2023 WCF Call with L. Despins regarding enforcement

notes regarding same (.1) 0.60 1,235.00 741.00 07/17/2023 DEB4 Correspond with S. Maza regarding Mahwah service issues 0.20 1,320.00 264.00 Date Initials Description Hours Rate Amount 07/17/2023 SM29 Email U.S. Marshals re stipulation with

07/18/2023 ECS1 Correspond with S. Maza about service of

adversary proceeding (.1); correspond with

07/18/2023 LAD4 T/c J. Tyminski (USMS) re: modification to proposed order (.40); t/c S. Maza re: same

07/18/2023 Analyze service of the Mahwah pleadings and TRO under FRCP and Nevada law 2.10 815.00 1,711.50 07/18/2023 Correspond with S. Maza on service of

07/18/2023 SM29 Correspond with L. Despins and re

comments and precedents (.2); call with L. Despins regarding comments on TRO (.4); prepare notice of same and revise TRO (.9) 1.50 1,320.00 1,980.00 07/19/2023 LAD4 Review/edit revised TRO order (.90); call W. Farmer and J. Tyminski (USMS) re: next

07/19/2023 Prepare revised proposed order regarding

07/19/2023 SM29 Prepare notice of revised proposed TRO and finalize for filing (.5); correspond with

re same (.3); email 1.00 1,320.00 1,320.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2369638

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2369638

Date Initials Description Hours Rate Amount

07/19/2023 WCF Analyze authorities regarding TRO enforcement (1.6); draft issues list regarding same (.2); call with J. Tyminski (USMS) and

07/20/2023 LAD4 T/c J. Murray (DOJ) re: prior entry 0.20 1,860.00 372.00 07/21/2023 LAD4 T/c R. Stout (FBI), J. Tyminski (USMS) re: prior entry (.20); t/c J. Murray (DOJ) re: update on same (.20) 0.40 1,860.00 744.00 07/24/2023 WCF Call with J. Tyminski, Agent Stout regarding

with L. Despins regarding same (.2) 0.50 1,235.00 617.50 07/25/2023 Analyze NFSC's live streaming activities in the Mahwah mansion and schedules of their

07/25/2023 WCF Correspond with J. Tyminski regarding

Subtotal: B191 General Litigation 86.90 98,916.00

ID Timekeeper Name Title Hours Rate Fees

LAD4 Luc A. Despins Partner 9.50 1,860.00 17,670.00 NAB Nicholas A. Bassett Partner 4.00 1,625.00 6,500.00 AB21 Alex Bongartz Of Counsel 0.10 1,625.00 162.50 AEL2 Luft, Avi E. Of Counsel 0.40 1,625.00 650.00 SM29 Shlomo Maza Associate 26.00 1,320.00 34,320.00 DEB4 Douglass E. Barron Associate 5.80 1,320.00 7,656.00 WCF Will C. Farmer Associate 3.30 1,235.00 4,075.50 ECS1 Ezra C. Sutton Associate 2.70 1,015.00 2,740.50

JK21 Jocelyn Kuo Paralegal 12.60 540.00 6,804.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2369638 Page 9

Date Description Quantity Rate Amount

07/18/2023 Filing Fee - Ezra Sutton; 07/11/2023; Filing fees in connection with an adversary proceeding filed in

07/23/2023 Computer Search (Other) 0.90 Total Costs incurred and advanced \$350.90

Total Balance Due - Due Upon Receipt \$99,266.90

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00013 Luc A. Despins

Legal fees for professional services for the period ending July 31, 2023 \$90,231.50

Total Balance Due - Due Upon Receipt \$91,426.35

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00013 Luc A. Despins

Legal fees for professional services for the period ending July 31, 2023 \$90,231.50

Total Balance Due - Due Upon Receipt \$91,426.35

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5270 of

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023

New York, NY 10166 Invoice Number: 2369639

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2023 Golden Spring Adversary Proceeding \$90,231.50

Date Initials Description Hours Rate Amount B191 General Litigation 07/05/2023 DEB4 Prepare parts of Golden Spring complaint 3.40 1,320.00 4,488.00 07/18/2023 DEB4 Prepare parts of Golden Spring complaint 7.80 1,320.00 10,296.00 07/19/2023 DEB4 Correspond with regarding complaint introduction 0.10 1,320.00 132.00 07/19/2023 DEB4 Correspond with regarding changes to Golden Spring complaint 0.30 1,320.00 396.00 07/19/2023 DEB4 Prepare parts of Golden Spring complaint 1.20 1,320.00 1,584.00 07/19/2023 DEB4 Correspond with regarding Golden Spring complaint 0.30 1,320.00 396.00 07/19/2023 DEB4 Analyze documents related to Golden Spring complaint 2.10 1,320.00 2,772.00 07/19/2023 LAD4 Review/edit complaint alter ego 1.70 1,860.00 3,162.00 07/19/2023 Review and prepare part of draft complaint against Golden Spring 2.50 815.00 2,037.50 07/20/2023 DEB4 Correspond with L. Despins regarding complaint (0.4); revise same (0.8); correspond with regarding same (0.2) 1.40 1,320.00 1,848.00

Date Initials Description Hours Rate Amount

07/20/2023 LAD4 Review/edit re-draft of complaint 1.10 1,860.00 2,046.00 07/20/2023 Correspond with D. Barron regarding comments on the Golden Spring complaint 0.20 815.00 163.00 07/21/2023 DEB4 Prepare parts of Golden Spring complaint 1.00 1,320.00 1,320.00 07/21/2023 DEB4 Correspond with L. Despins regarding

07/21/2023 DEB4 Correspond with A. Luft regarding Golden

07/21/2023 JK21 Correspond with E. Sutton regarding

status with the state of New York 0.30 540.00 162.00 07/21/2023 AEL2 Review documents to be used as exhibits 1.30 1,625.00 2,112.50 07/21/2023 Revise Golden Spring adversary complaint 1.00 815.00 815.00 07/22/2023 AEL2 Prepare parts of draft complaint against

07/23/2023 DEB4 Prepare parts of Golden Spring complaint 1.20 1,320.00 1,584.00 07/23/2023 DEB4 Correspond with A. Luft and N. Bassett regarding complaint 0.80 1,320.00 1,056.00

complaint and exhibits 0.40 1,320.00 528.00 07/23/2023 DEB4 Correspond with A. Chon and S. Zhu regarding Hong Kong service 0.10 1,320.00 132.00

07/23/2023 DEB4 Correspond with S. Maza on turnover

07/23/2023 AEL2 Correspond with D. Barron and N. Bassett re: potential claims for complaint 0.40 1,625.00 650.00 07/23/2023 Prepare exhibits and revise citations for Golden Spring complaint 6.30 815.00 5,134.50 Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5272 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00013 Invoice No. 2369639

Date Initials Description Hours Rate Amount 07/23/2023 Conference with D. Barron regarding comments on Golden Spring complaint and exhibits (.4); correspond with D. Barron regarding same (.1) 0.50 815.00 407.50 07/23/2023 NAB Review and revise draft complaint (1.3); correspond with D. Barron and A. Luft regarding same (.3) 1.60 1,625.00 2,600.00 07/24/2023 DEB4 Correspond with regarding sealing motion 0.20 1,320.00 264.00 07/24/2023 DEB4 Correspond with regarding complaint exhibits 0.40 1,320.00 528.00 07/24/2023 DEB4 Revise sealing motion 0.60 1,320.00 792.00 07/24/2023 DEB4 Correspond with S. Zhu regarding Hong Kong service 0.10 1,320.00 132.00 07/24/2023 DEB4 Conferences with regarding Golden Spring complaint and motion to seal 0.60 1,320.00 792.00 07/24/2023 DEB4 Correspond with E. Sutton regarding sealing motion 0.10 1,320.00 132.00 07/24/2023 DEB4 Correspond with regarding exhibits to Golden Spring complaint 0.40 1,320.00 528.00 07/24/2023 DEB4 Correspond with L. Despins regarding complaint 0.20 1,320.00 264.00 07/24/2023 DEB4 Conferences with N. Bassett regarding complaint 0.20 1,320.00 264.00 07/24/2023 DEB4 Revise Golden Spring complaint 2.70 1,320.00 3,564.00 07/24/2023 DEB4 Conference with L. Despins regarding complaint 0.20 1,320.00 264.00 07/24/2023 ECS1 Prepare motion to seal complaint against Golden Spring (.2); correspond with D. Barron regarding same (.1) 0.30 1,015.00 304.50 07/24/2023 ECS1 Analyze authority regarding service of summons and complaint on foreign corporation in Hong Kong (1.3); prepare summary of findings regarding same (.9) 2.20 1,015.00 2,233.00 07/24/2023 JK21 Prepare redacted exhibits for Golden Spring 2.30 540.00 1,242.00 Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5273 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00013 Invoice No. 2369639

Date Initials Description Hours Rate Amount

07/24/2023 LAD4 Final review/edit of complaint (.70); t/c D. Barron re: same (.20) 0.90 1,860.00 1,674.00 07/24/2023 Phone call with D. Barron on the motion to seal complaint against Golden Spring 0.30 815.00 244.50 07/24/2023 Prepare exhibits to be filed with Golden

07/24/2023 Prepare parts of Golden Spring complaint 3.20 815.00 2,608.00 07/24/2023 Phone call with D. Barron on the Golden

07/24/2023 NAB Review Golden Spring adversary complaint (.2); correspond with D. Barron regarding same (.4); calls with D. Barron regarding

regarding same (.1) 0.90 1,625.00 1,462.50 07/25/2023 DEB4 Correspond with A. Chan regarding Hong Kong service issues 0.10 1,320.00 132.00 07/25/2023 DEB4 Correspond with S. Sarnoff (OMM) regarding Golden Spring complaint 0.10 1,320.00 132.00 07/25/2023 DEB4 Correspond with N. Bassett regarding motion to seal (0.1); analyze same (0.5) 0.60 1,320.00 792.00 07/25/2023 DEB4 Revise Golden Spring complaint 0.80 1,320.00 1,056.00 07/25/2023 DEB4 Call with N. Bassett regarding complaint 0.10 1,320.00 132.00 07/25/2023 DEB4 Correspond with N. Bassett regarding

07/25/2023 DEB4 Correspond with J. Kuo regarding filing of Golden Spring complaint 0.30 1,320.00 396.00 07/25/2023 DEB4 Call with E. Sutton regarding Hong Kong

07/25/2023 ECS1 Call with D. Barron regarding service of

corporation in Hong Kong 0.20 1,015.00 203.00 07/25/2023 ECS1 Correspond with D. Barron regarding 0.20 1,015.00 203.00

Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5274 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00013 Invoice No. 2369639

Date Initials Description Hours Rate Amount

07/25/2023 JK21 Prepare Golden Spring complaint and exhibits for electronic filing (2.5); electronically file with the court complaint

07/25/2023 Review and revise exhibits to the Golden Spring complaint for filing 1.00 815.00 815.00 07/25/2023 NAB Review draft complaint and motion to seal (.6); correspond with L. Despins and D.

(.3); call with D. Barron regarding same (.1) 1.00 1,625.00 1,625.00 07/27/2023 DEB4 Correspond with E. Sutton regarding Golden Spring service issues 0.30 1,320.00 396.00 07/27/2023 DEB4 Correspond with H. Claiborn (UST) regarding Golden Spring complaint 0.20 1,320.00 264.00 07/27/2023 DEB4 Correspond with J. Kuo regarding Golden

07/27/2023 DEB4 Correspond with D. Mohamed regarding Golden Spring complaint exhibits 0.10 1,320.00 132.00 07/27/2023 ECS1 Correspond with D. Barron and A. Chan

07/27/2023 Review China Golden Spring corporate

07/28/2023 DEB4 Correspond with J. Murray (DOJ) regarding contempt decision 0.20 1,320.00 264.00 07/28/2023 ECS1 Review certificates of service in connection

(.1); correspond with D. Barron and P. Linsey (NPM) regarding same (.2) 0.30 1,015.00 304.50 07/28/2023 ECS1 Review and comment on service of Golden Spring adversary proceeding (.6);

07/31/2023 DEB4 Call with E. Sutton regarding Golden Spring service issues 0.10 1,320.00 132.00 Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5275 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00013 Invoice No. 2369639

Date Initials Description Hours Rate Amount

07/31/2023 ECS1 Review and comment on service of Golden Spring adversary proceeding (.8); call with D. Barron about the same (.1) 0.90 1,015.00 913.50 Subtotal: B191 General Litigation 77.90 90,231.50

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 3.70 1,860.00 6,882.00 NAB Nicholas A. Bassett Partner 3.50 1,625.00 5,687.50 AEL2 Luft, Avi E. Of Counsel 6.60 1,625.00 10,725.00 DEB4 Douglass E. Barron Associate 30.10 1,320.00 39,732.00 ECS1 Ezra C. Sutton Associate 6.00 1,015.00 6,090.00

JK21 Jocelyn Kuo Paralegal 6.20 540.00 3,348.00

Date Description Quantity Rate Amount

07/12/2023 Photocopy Charges 101.00 0.08 8.08 07/12/2023 Photocopy Charges 101.00 0.08 8.08 07/31/2023 Photocopy Charges 11,408.00 0.08 912.64

07/28/2023 Computer Search (Other) 0.36 Case 22-50073 Doc 2256 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5276 of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 7

07/31/2023 Search Fee - Companies Registry, Invoice# 6.79 20230731PT Dated 07/31/23, company search fee on 28 July 2023 for 1 company; requested by Ezra

Total Costs incurred and advanced \$1,194.85

Total Balance Due - Due Upon Receipt \$91,426.35 Case 22-50073r-Ddd 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 21Page 527 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

HCHK Adversary Proceeding PH LLP Client/Matter # 50687-00014

Legal fees for professional services for the period ending July 31, 2023 \$355,217.75

Total Balance Due - Due Upon Receipt \$356,551.69

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-Ddd 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 21Page 528 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00014 Luc A. Despins

Legal fees for professional services for the period ending July 31, 2023 \$355,217.75

Total Balance Due - Due Upon Receipt \$356,551.69

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:\nPaul Hastings LLP\nLockbox 4803\nPO Box 894803\nLos Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-Ddd 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 21Page 529 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2023

Date Initials Description Hours Rate Amount

07/11/2023 LAD4 Continue to review issues and prepare hearing outline (1.50); handle hearing on settlement and related discussions (4.10) 5.60 1,860.00 10,416.00 07/11/2023 AEL2 Attend part of rule 9019 hearing for HCHK 2.00 1,625.00 3,250.00 07/18/2023 LAD4 Continue to review issues and prepare hearing outline (1.20); handle hearing (3.10); t/c D. Barron re: same (.20) 4.50 1,860.00 8,370.00 07/18/2023 AEL2 Attend hearing re: HCHK settlement

Subtotal: B155 Court Hearings 14.30 25,611.00

07/03/2023 DEB4 Correspond with L. Despins regarding informant email on HCHK issues 0.10 1,320.00 132.00

Date Initials Description Hours Rate Amount 07/03/2023 ECS1 Correspond with N. Bassett, A. Luft, M.

the HCHK adversary proceeding 0.30 1,015.00 304.50 07/03/2023 ECS1 Review invoices of expenses in connection

07/03/2023 KC27 Analyze case law regarding court's discretion in setting terms of injunction (.9);

07/03/2023 NAB Correspond with L. Despins and A. Luft regarding HCHK litigation and G News 0.30 1,625.00 487.50 07/05/2023 DEB4 Correspond with L. Despins regarding assignee counsel fees 0.10 1,320.00 132.00 07/05/2023 DEB4 Correspond with E. Sutton regarding assignee counsel fees 0.20 1,320.00 264.00 07/05/2023 ECS1 Call with A. Luft, M. Pena (Norris

HCHK adversary proceeding 0.50 1,015.00 507.50 07/05/2023 ECS1 Continue to review invoices of expenses in

summary of same (.6) 2.20 1,015.00 2,233.00 07/05/2023 KC27 Analyze case law regarding co-defendant

07/05/2023 AEL2 Analyze and comment on response to G Club objection to settlement motion 1.00 1,625.00 1,625.00 07/05/2023 AEL2 Meet and confer with counsel for G News and E. Sutton re: potential sale of assets 0.50 1,625.00 812.50 07/05/2023 NAB Review draft motion to set answer deadline in HCHK litigation (.4); correspond with L. 0.70 1,625.00 1,137.50 Date Initials Description Hours Rate Amount 07/06/2023 DEB4 Conference with A. Luft regarding HCHK

07/06/2023 DEB4 Correspond with M. Tsukerman (CS) regarding assignee expenses 0.20 1,320.00 264.00 07/06/2023 DEB4 Conference with K. Catalano regarding alter

07/06/2023 DEB4 Correspond with L. Despins regarding assignee expenses 0.30 1,320.00 396.00 07/06/2023 DEB4 Conference with P. Linsey (NPM) regarding

Himalaya activities 0.30 1,320.00 396.00 07/06/2023 DEB4 Conference with M. Tsukerman (CS)

07/06/2023 DEB4 Prepare reply in support of HCHK rule

07/06/2023 DEB4 Conference with J. Austin regarding research on entity documents 0.10 1,320.00 132.00 07/06/2023 ECS1 Correspond with D. Barron, P. Linsey

regarding transcript of June 27, 2023 status conference in HCHK adversary proceeding 0.20 1,015.00 203.00 07/06/2023 ECS1 Analyze case law and statutory authority regarding non-party's standing to object to

about same (.4) 3.20 1,015.00 3,248.00 07/06/2023 ECS1 Review discovery documents in connection with Trustee's reply in support of rule 9019

(2.0); prepare summary of same for D.

Date Initials Description Hours Rate Amount 07/06/2023 KC27 Analyze case law regarding standing of creditors of alter ego entity in adversary proceeding (5.1); conference with D. Barron

(1.7); analyze case law regarding standing pursuant to section 1109 of the Bankruptcy

07/06/2023 AEL2 Analyze objections to the HCHK settlement motion 2.10 1,625.00 3,412.50 07/06/2023 AEL2 Call with D. Barron re: arguments for rule

07/06/2023 AEL2 Review information on 133256 B.C. Ltd.,

League, Inc., Kalixun Trading Limited, and

07/06/2023 AEL2 Analyze case law on identifying proper defendants for alter ego claims 1.20 815.00 978.00 07/07/2023 DEB4 Correspond with K. Catalano regarding alter ego findings 0.30 1,320.00 396.00 07/07/2023 DEB4 Call with A. Luft regarding HCHK reply in support of rule 9019 motion 0.40 1,320.00 528.00 07/07/2023 DEB4 Correspond with L. Despins regarding U.S.

07/07/2023 DEB4 Correspond with H. Claiborn (US Trustee) regarding rule 9019 order 0.10 1,320.00 132.00 07/07/2023 DEB4 Correspond with L. Despins regarding deed

07/07/2023 DEB4 Correspond with M. Tsukerman (CS) and R. Jareck (CS) regarding reply in support of rule 9019 motion 0.80 1,320.00 1,056.00 07/07/2023 DEB4 Correspond with M. Tsukerman regarding assignee expenses 0.10 1,320.00 132.00 07/07/2023 DEB4 Correspond with L. Despins regarding assignee expenses 0.10 1,320.00 132.00 Date Initials Description Hours Rate Amount 07/07/2023 DEB4 Prepare HCHK reply in support of rule

07/07/2023 DEB4 Correspond with E. Sutton regarding case law on rule 9019 standing 0.30 1,320.00 396.00

07/07/2023 DEB4 Revise assignee filing re: rule 9019 motion 0.50 1,320.00 660.00 07/07/2023 DEB4 Correspond with M. Tsukerman regarding exculpation issue 0.10 1,320.00 132.00 07/07/2023 ECS1 Prepare reply in support of rule 9019

(3.3); analyze case law in connection with same (.6); prepare certificate of service regarding same (.3); correspond with D.

supporting case law, and service (.7) 4.90 1,015.00 4,973.50 07/07/2023 JK21 Review and comment on service of reply in support of rule 9019 motion 0.20 540.00 108.00 07/07/2023 KC27 Analyze case law regarding standing of alter ego entities' creditors and equity holders

07/07/2023 LAD4 Review HCHK response 0.80 1,860.00 1,488.00 07/07/2023 AEL2 Correspond with D. Barron re: arguments and comments for rule 9019 reply brief 1.90 1,625.00 3,087.50 07/07/2023 AEL2 Call with D. Barron re: arguments for rule

07/07/2023 AEL2 Draft parts of reply brief to objections to settlement motion 3.50 1,625.00 5,687.50 07/07/2023 AEL2 Review and comment on draft reply to objection to settlement motion 1.90 1,625.00 3,087.50 07/07/2023 AEL2 Analyze Himalaya objection to settlement

07/07/2023 AEL2 Call with Cole Schotz re: its rule 9019 reply brief, authority, and argument 0.90 1,625.00 1,462.50 Case 22-50073r-Ddd 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 21Page 530 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Case 22-50073r-Ddd 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 21Page 531 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Date Initials Description Hours Rate Amount 07/07/2023 Analyze information related to 133256 B.C. Ltd. and its signatory Yanchun Liu 1.00 815.00 815.00 07/09/2023 DEB4 Correspond with N. Bassett and L. Despins regarding HCHK issues 0.40 1,320.00 528.00 07/09/2023 ECS1 Analyze case law on impact of rule 9019 settlement agreement on third parties 0.60 1,015.00 609.00 07/09/2023 NAB Correspond with L. Despins regarding HCHK litigation issues and strategy (.2); analyze same (.3) 0.50 1,625.00 812.50 07/10/2023 DEB4 Conference with L. Despins, A. Luft, R. Jareck (CS), M. Tsukerman (CS) regarding rule 9019 hearing and plan for same 0.50 1,320.00 660.00 07/10/2023 DEB4 Correspond with S. Shelley regarding assignment issues 0.20 1,320.00 264.00 07/10/2023 DEB4 Correspond with L. Despins regarding rule 9019 hearing 0.20 1,320.00 264.00 07/10/2023 DEB4 Prepare documents for HCHK hearing on settlement agreement 2.40 1,320.00 3,168.00 07/10/2023 DEB4 Analyze HCHK documents in connection with rule 9019 motion and settlement 1.20 1,320.00 1,584.00 07/10/2023 DEB4 Correspond with M. Tsukerman (CS) regarding assignee expenses 0.10 1,320.00 132.00 07/10/2023 DEB4 Follow up conference with A. Luft regarding rule 9019 hearing prep 0.40 1,320.00 528.00 07/10/2023 DEB4 Correspond with L. Despins regarding Cole Schotz fees in connection with settlement 0.10 1,320.00 132.00 07/10/2023 DEB4 Correspond with E. Sutton regarding Cole Schotz fees in connection with settlement 0.20 1,320.00 264.00 07/10/2023 ECS1 Prepare documents and case annotations for 7/11/23 hearing in HCHK adversary proceeding (3.2); correspond with D. Barron about same (.3) 3.50 1,015.00 3,552.50 07/10/2023 JK21 Serve, electronically and by hard copy, rule 9019 reply brief 0.60 540.00 324.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Date Initials Description Hours Rate Amount

07/10/2023 LAD4 Review submissions, issues and prepare outline for Rule 9019 hearing (1.6); t/c R. Jareck (CS), M. Tsukerman (CS), D. Barron, A. Luft re: same (.5) 2.10 1,860.00 3,906.00 07/10/2023 AEL2 Call with N. Bassett re: HCHK arguments for rule 9019 settlement hearing 0.30 1,625.00 487.50 07/10/2023 AEL2 Call with D. Barron re: prep for tomorrow's hearing on rule 9019 motion 0.40 1,625.00 650.00 07/10/2023 AEL2 Review rule 9019 submissions in preparation for settlement hearing 2.40 1,625.00 3,900.00 07/10/2023 AEL2 Prepare notes for call with Cole Schotz regarding settlement motion and hearing 0.20 1,625.00 325.00 07/10/2023 AEL2 Call with L. Despins, D. Barron, R. Jareck (CS), M. Tsukerman (CS) re: arguments for rule 9019 settlement motion and hearing 0.50 1,625.00 812.50 07/10/2023 NAB Correspond with A. Luft regarding hearing

regarding same (.3) 0.50 1,625.00 812.50 07/11/2023 AB21 Correspond with L. Despins and D. Barron

07/11/2023 DEB4 Correspond with L. Despins regarding rule

07/11/2023 DEB4 Correspond with L. Despins regarding HCHK rule 9019 order 0.10 1,320.00 132.00 07/11/2023 DEB4 Conference with E. Sutton regarding assignee counsel fees 0.10 1,320.00 132.00 07/11/2023 DEB4 Correspond with A. Luft regarding assignee

07/11/2023 DEB4 Correspond with L. Despins regarding HCHK assignee settlement 0.10 1,320.00 132.00 07/11/2023 DEB4 Correspond with R. Jareck (CS) regarding revised proposed rule 9019 order (0.2); correspond with E. Sutton regarding same 0.30 1,320.00 396.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Date Initials Description Hours Rate Amount 07/11/2023 DEB4 Correspond with E. Sutton regarding motion for answer deadline 0.10 1,320.00 132.00 07/11/2023 ECS1 Revise proposed rule 9019 order in connection with HCHK settlement agreement 0.50 1,015.00 507.50 07/11/2023 ECS1 Prepare Rule 7012 motion in HCHK adversary proceeding 0.50 1,015.00 507.50 07/11/2023 ECS1 Outline argument for 7/11/23 hearing in HCHK adversary proceeding (.7); correspond with D. Barron and A. Luft about same (.1); call with D. Barron regarding assignee counsel fees (.1) 0.90 1,015.00 913.50 07/11/2023 AEL2 Review submissions and case law in preparation for settlement hearing oral argument 1.10 1,625.00 1,787.50 07/11/2023 AEL2 Review and supplement outline for rule 9019 settlement hearing 2.70 1,625.00 4,387.50 07/11/2023 AEL2 Correspond with L. Despins and N. Bassett re: HCHK rule 9019 settlement hearing (.1); revise rule 9019 order (.1) 0.20 1,625.00 325.00 07/12/2023 DEB4 Conferences with E. Sutton regarding service issues 0.20 1,320.00 264.00 07/12/2023 DEB4 Conference with A. Luft regarding HCHK hearing on settlement motion and changes to proposed rule 9019 order 0.40 1,320.00 528.00 07/12/2023 DEB4 Revise rule 9019 order 0.30 1,320.00 396.00 07/12/2023 DEB4 Conference with A. Luft regarding revised rule 9019 order 0.10 1,320.00 132.00 revised rule 9019 order

07/12/2023 DEB4 Conference with E. Sutton regarding 0.10 1,320.00 132.00 07/12/2023 ECS1 Analyze service issues in HCHK adversary proceeding (.9); call with D. Barron regarding same (.2) 1.10 1,015.00 1,116.50 07/12/2023 ECS1 Prepare revised proposed order on rule 9019 motion (.6); call with D. Barron about same (.1) 0.70 1,015.00 710.50

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Date Initials Description Hours Rate Amount

07/12/2023 ECS1 Prepare Rule 7012 motion in HCHK adversary proceeding 0.40 1,015.00 406.00 07/12/2023 KC27 Analyze case law regarding impact of equitable ownership finding 1.00 915.00 915.00 07/12/2023 AEL2 Correspond with D. Barron re: revised terms of proposed HCHK rule 9019 order 0.20 1,625.00 325.00 07/12/2023 AEL2 Meet with D. Barron re: hearing and

07/12/2023 AEL2 Call with D. Barron re: edits to proposed

07/13/2023 DEB4 Call with E. Sutton regarding revised

same (.1); correspond with R. Jareck (CS) regarding same (0.1) 0.80 1,320.00 1,056.00 07/13/2023 DEB4 Correspond with L. Despins regarding revised proposed rule 9019 order 0.10 1,320.00 132.00 07/13/2023 DEB4 Revise DOJ stipulation (0.3); correspond with L. Despins regarding same (0.1); correspond with J. Murray (DOJ) regarding

07/13/2023 DEB4 Correspond with P. Linsey (NPM) regarding revised proposed Rule 9019 order 0.10 1,320.00 132.00 07/13/2023 ECS1 Prepare revised proposed order on rule 9019 motion (.7); call with D. Barron about

07/13/2023 ECS1 Prepare Rule 7012 motion in HCHK adversary proceeding (.6); correspond with N. Bassett and P. Linsey (NPM) about same

07/13/2023 ECS1 Correspond with J. Kuo and D. Barron

Date Initials Description Hours Rate Amount 07/13/2023 JK21 Prepare for filing proposed order regarding settlement agreement with assignee (0.3); electronically file with the court proposed order regarding settlement agreement with assignee (0.4); electronically serve proposed order regarding settlement agreement with

07/13/2023 KC27 Analyze case law regarding standing for substantive consolidation (1.9); correspond with D. Barron regarding same (.2) 2.10 915.00 1,921.50 07/13/2023 LAD4 Review/edit revised order 0.70 1,860.00 1,302.00 07/13/2023 AEL2 Correspond with P. Linsey and D. Barron re: process for service of revised rule 9019

07/13/2023 NAB Correspond with P. Linsey (NPM)

07/14/2023 DEB4 Correspond with E. Sutton regarding assignee documents 0.10 1,320.00 132.00 07/14/2023 DEB4 Correspond with K. Catalano regarding

07/14/2023 DEB4 Correspond with L. Despins and A. Luft

07/14/2023 DEB4 Correspond with R. Jareck (CS) regarding assignee documents 0.10 1,320.00 132.00 07/14/2023 DEB4 Conference with R. Jareck (CS) regarding

07/14/2023 ECS1 Review service issues in HCHK adversary

07/14/2023 ECS1 Review and comment on service of Rule

proceeding (.1); prepare certificate of 0.20 1,015.00 203.00 Date Initials Description Hours Rate Amount 07/14/2023 JK21 Prepare certificate of service regarding pretrial scheduling order (0.6); electronically file with the court certificate of service regarding pretrial scheduling order (0.3) 0.90 540.00 486.00 07/14/2023 JK21 Review and comment on hard copy and electronic service of Rule 7012 motion 0.40 540.00 216.00 07/14/2023 LAD4 Conduct due diligence re: releases to assignee, et al (3.20); t/c and emails R. Jareck (CS) re: same (.50) 3.70 1,860.00 6,882.00 07/14/2023 Phone call with informant on the operation of farms, farm loan project, and companies associated with the farm 0.90 815.00 733.50 07/14/2023 Prepare memo on the operation and structure of farms, farm loan project, and HCHK's involvement in the loan project 2.00 815.00 1,630.00 07/14/2023 Review and summarize informant's email on HCHK and Yanchun Liu 0.50 815.00 407.50 07/16/2023 DEB4 Correspond with L. Despins regarding rule

07/17/2023 DEB4 Conference with A. Luft regarding HCHK rule 9019 issues (1.7); analyze submissions and cases for hearing related to same (2.3) 4.00 1,320.00 5,280.00 07/17/2023 DEB4 Correspond with E. Sutton regarding G-

07/17/2023 DEB4 Conference with E. Sutton regarding reference materials for continued settlement

07/17/2023 DEB4 Correspond with L. Despins regarding intervention motion 0.20 1,320.00 264.00 07/17/2023 DEB4 Conference with E. Sutton regarding service

07/17/2023 DEB4 Correspond with A. Luft regarding continued rule 9019 hearing 0.30 1,320.00 396.00 07/17/2023 DEB4 Conference with regarding Himalaya Farm witness 0.30 1,320.00 396.00 Date Initials Description Hours Rate Amount 07/17/2023 ECS1 Review submissions and related HCHK

agreement (.3); conference with D. Barron regarding same (.4) 0.70 1,015.00 710.50 07/17/2023 ECS1 Review service issues in HCHK adversary proceeding (.1); conference with D. Barron regarding same (.2) 0.30 1,015.00 304.50 07/17/2023 JK21 Correspond with E. Sutton regarding rule

07/17/2023 LAD4 Review submissions, issues and prepare outline for hearing (3.10); t/c R. Jareck (CS) re: same (.30) 3.40 1,860.00 6,324.00 07/17/2023 AEL2 Call with N. Bassett re: HCHK sur-

07/17/2023 AEL2 Analyze and comment on arguments in

settlement motion and order 1.20 1,625.00 1,950.00 07/17/2023 AEL2 Meet with D. Barron re: objection response and prep for continued rule 9019 hearing 1.70 1,625.00 2,762.50 07/17/2023 AEL2 Analyze objections to rule 9019 motion and

07/17/2023 Review loan agreements between HCHK and the intervenor entities 1.30 815.00 1,059.50 07/17/2023 Review corporate documents of 133256

07/17/2023 Phone call with D. Barron regarding the

07/17/2023 Review documents on Relativity for

director of 133256 B.C. Ltd. 0.50 815.00 407.50 07/17/2023 NAB Call with A. Luft regarding continued

objection and discovery issues (.3); review documents related to same (.1) 0.40 1,625.00 650.00 Date Initials Description Hours Rate Amount 07/18/2023 DEB4 Conference with L. Despins regarding hearing on HCHK settlement motion 0.20 1,320.00 264.00 07/18/2023 DEB4 Conference with A. Luft regarding rule 9019 hearing arguments 0.20 1,320.00 264.00 07/18/2023 DEB4 Analyze corporate documents from purported HCHK creditors 0.30 1,320.00 396.00

purported HCHK creditors 0.20 1,320.00 264.00 07/18/2023 ECS1 Analyze authority regarding service via mail under Rule 7004(b) 0.70 1,015.00 710.50 07/18/2023 AEL2 Correspond with N. Bassett re: HCHK objection responses 0.30 1,625.00 487.50 07/18/2023 AEL2 Draft talking points for HCHK hearing on settlement motion (1.9); conference with D. Barron regarding same (.2) 2.10 1,625.00 3,412.50 07/18/2023 AEL2 Correspond with D. Barron, E. Sutton re: action items arising from rule 9019 hearing 0.30 1,625.00 487.50 07/18/2023 Review documents on Relativity for

07/19/2023 DEB4 Correspond with K. Catalano regarding

07/19/2023 DEB4 Conference with L. Despins, N. Bassett, A

07/19/2023 DEB4 Review findings from K. Catalano regarding

07/19/2023 DEB4 Conference with A. Luft regarding HCHK issues and post-hearing items 0.60 1,320.00 792.00

07/19/2023 DEB4 Correspond with E. Sutton regarding

Date Initials Description Hours Rate Amount 07/19/2023 ECS1 Prepare requests for production, admissions

about same (.4) 4.20 1,015.00 4,263.00 07/19/2023 ECS1 Call with L. Despins, N. Bassett, A. Luft

proposed intervenors 0.50 1,015.00 507.50 07/19/2023 ECS1 Correspond with D. Barron and A. Luft

07/19/2023 KC27 Analyze case law regarding standing for creditor of creditor (1.9); summarize same (.2); correspond with D. Barron regarding

07/19/2023 LAD4 Review/comment on discovery issues re: intervenors (1.90); t/c D. Barron, N. Bassett, E. Sutton, A. Luft re: same (.50) 2.40 1,860.00 4,464.00 07/19/2023 AEL2 Draft parts of intervenor discovery 5.50 1,625.00 8,937.50 07/19/2023 AEL2 Call with D. Barron re: action items from

07/19/2023 AEL2 Meeting with L. Despins, N. Bassett, D.

intervention discovery 0.50 1,625.00 812.50 07/19/2023 AEL2 Correspond with R. Jareck (CS) re: intervention evidence 0.40 1,625.00 650.00 07/19/2023 AEL2 Call with J. Sherman re: claim in HCHK 0.40 1,625.00 650.00 07/19/2023 AEL2 Correspond with Pastore firm re: intervention motion 0.20 1,625.00 325.00 07/19/2023 AEL2 Analyze intervention motion 0.90 1,625.00 1,462.50 07/19/2023 Prepare request for production, interrogatories, and request for admissions to the proposed intervenors (1.7); calls with E. Sutton regarding same (.4) 2.10 815.00 1,711.50 07/19/2023 Review corporate documents for Japanese Himalaya League, Inc. 0.20 815.00 163.00 Date Initials Description Hours Rate Amount 07/19/2023 NAB Call with L. Despins, A. Luft, D. Barron,

07/20/2023 DEB4 Correspond with R. Jareck (CS) regarding

regarding Xvebing Wang 0.10 1,320.00 132.00 07/20/2023 DEB4 Correspond with E. Sutton regarding CHOCK service list 0.10 1,320.00 132.00 07/20/2023 DEB4 Conference with A. Luft related to standing and interrogatories 0.60 1,320.00 792.00 07/20/2023 DEB4 Analyze HCHK loan documents (1.2);

(0.3); prepare summary analysis regarding

07/20/2023 DEB4 Conference with A. Luft regarding intervention discovery 0.50 1,320.00 660.00 07/20/2023 DEB4 Conference with A. Luft, W. Farmer, N.

intervention discovery 0.30 1,320.00 396.00 07/20/2023 DEB4 Call with E. Sutton regarding requests for

07/20/2023 DEB4 Analyze authorities regarding intervention discovery issues 0.80 1,320.00 1,056.00 07/20/2023 ECS1 Analyze authority on standards in connection with intervention in adversary proceeding (.5); draft summary of findings regarding same (.2) 0.70 1,015.00 710.50 07/20/2023 ECS1 Call with P. Linsey (NPM) regarding service in HCHK adversary proceeding 0.10 1,015.00 101.50

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Case 22-50073r-D0d 2255 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5291 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640 Case 22-50073r-D0d 2255 Filed 10/16/23 Entered 10/16/23 22:05:06 Page 5292 of 486

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Date Initials Description Hours Rate Amount 07/20/2023 ECS1 Prepare requests for production, admissions, interrogatories, deposition notices and subpoenas for proposed intervenors in HCHK adversary proceeding (5.0); correspond with N. Bassett, W. Farmer, A. Luft and regarding same (.4); call with D. Barron regarding same (.2); further correspond with regarding same (.2) 5.80 1,015.00 5,887.00 07/20/2023 AEL2 Meet and confer with R. Pastore, N. Bassett, D. Barron, W. Farmer re: intervention discovery 0.30 1,625.00 487.50 07/20/2023 AEL2 Call with D. Barron re: underlying HCHK loan documents 0.60 1,625.00 975.00 07/20/2023 AEL2 Review issues and notes to prepare for meet and confer with R. Pastore 0.40 1,625.00 650.00 07/20/2023 AEL2 Call with N. Bassett re: HCHK meet and confer follow up analysis 0.30 1,625.00 487.50 07/20/2023 AEL2 Call with D. Barron re: Rule 26 and HCHK intervention 0.50 1,625.00 812.50 07/20/2023 AEL2 Prepare parts of discovery requests and subpoenas 3.70 1,625.00 6,012.50 07/20/2023 AEL2 Correspond with E. Sutton re: edits to requests for admission 0.30 1,625.00 487.50 07/20/2023 Review and prepare memo on the HCHK loan agreements with the proposed intervenors (1.6); calls with D. Barron regarding same (.3) 1.90 815.00 1,548.50 07/20/2023 Prepare request for production, interrogatories, and request for admissions to the proposed intervenors 1.00 815.00 815.00 07/20/2023 Prepare notices of deposition and subpoenas to the proposed intervenors, each signatory, and Xuebing Wang 3.10 815.00 2,526.50

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Date Initials Description Hours Rate Amount

07/20/2023 NAB Review and revise draft discovery requests

, A. Luft regarding 2.30 1,625.00 3,737.50

07/20/2023 NAB Review and revise draft discovery requests

same (.2); call with A. Luft regarding same (.3); call with D. Barron, A. Luft, W.

same (.3); correspond with A. Luft, W.

related to discovery requests (.2); further review draft discovery requests (.4) 2.30 1,625.00 3,737.50

07/20/2023 WCF Meet and confer with Pastore LLP, A. Luft,

discovery and motion to intervene (.3);

07/20/2023 WCF Review motion to intervene arguments 0.30 1,235.00 370.50 07/21/2023 DEB4 Correspond with R. Jareck regarding

07/21/2023 DEB4 Correspond with A. Luft and L. Despins regarding HCHK witnesses 0.20 1,320.00 264.00 07/21/2023 DEB4 Conference with R. Jareck regarding

07/21/2023 ECS1 Prepare requests for production,

(2.8); correspond with N. Bassett, W.

07/21/2023 LAD4 Review/edit proposed discovery 0.90 1,860.00 1,674.00 07/21/2023 AEL2 Draft intervention discovery 2.80 1,625.00 4,550.00 07/21/2023 AEL2 Correspond with N. Bassett re: intervenors 0.60 1,625.00 975.00 07/21/2023 AEL2 Correspond with E. Sutton re: service issues 0.50 1,625.00 812.50

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Date Initials Description Hours Rate Amount 07/21/2023 Review HCHK loan agreement and Xuebing Wang's power of attorney agreement 1.20 815.00 978.00 07/21/2023 Prepare rule 30(b)(6) deposition notices to each intervenor party and notice to Xuebing Wang 2.30 815.00 1,874.50 07/21/2023 NAB Correspond with A. Luft regarding draft discovery requests (.4); review same (.1) 0.50 1,625.00 812.50 07/21/2023 WCF Correspond with N. Bassett and criminal counsel to Debtor and Y. Wang regarding discovery for motion to intervene 0.40 1,235.00 494.00 07/23/2023 DEB4 Correspond with W. Farmer regarding discovery issues and related case law 0.10 1,320.00 132.00 07/23/2023 DEB4 Correspond with regarding Xuebing Wang 0.10 1,320.00 132.00 07/23/2023 Correspond with informant on farm loan program and form loan agreement 0.50 815.00 407.50 07/23/2023 Review form loan agreement, addendum, and farm qualification document from informant 0.60 815.00 489.00 07/24/2023 DEB4 Correspond with L. Despins, N. Bassett and A. Luft regarding Holy City answer deadline 0.10 1,320.00 132.00 07/24/2023 ECS1 Analyze case law regarding application of standards in connection with intervention in adversary proceeding 0.30 1,015.00 304.50 07/24/2023 ECS1 Correspond with P. Linsey (NPM) regarding order setting answer deadline for Holy City and certificate of service regarding same (.2); review certificate of service regarding same (.2) 0.40 1,015.00 406.00 07/24/2023 ECS1 Review correspondence with defense counsel regarding requests for production, admissions, interrogatories, deposition notices and subpoenas for proposed intervenors in HCHK adversary proceeding (.1); correspond with L. Despins and N. Bassett about same (.1) 0.20 1,015.00 203.00

Date Initials Description Hours Rate Amount

07/24/2023 Review information on entities owned by

07/24/2023 NAB Correspond with W. Farmer regarding

preparation for calls with opposing counsel (.4); call with Debtor's counsel and W. Farmer regarding deposition of Debtor (.3);

regarding deposition of Y. Wang (.3); call with W. Farmer regarding same (.1); correspond with L. Despins regarding same

07/24/2023 WCF Call with Kwok criminal counsel and N.

motion to intervene (.3); follow-up call with N. Bassett regarding same (.1); call with Y.

regarding same (.3) 0.70 1,235.00 864.50 07/25/2023 DEB4 Correspond with regarding Himalaya entities 0.20 1,320.00 264.00 07/25/2023 DEB4 Correspond with D. Smith (DLA) regarding

07/25/2023 DEB4 Analyze case law on intervention issues 2.50 1,320.00 3,300.00 07/25/2023 DEB4 Correspond with N. Bassett regarding motion to modify TRO 0.50 1,320.00 660.00 07/25/2023 DEB4 Correspond with R. Jareck (CS) regarding

07/25/2023 DEB4 Analyze motion to modify TRO (0.5); correspond with L. Despins regarding same

regarding same (0.1) 0.70 1,320.00 924.00 07/25/2023 DEB4 Correspond with N. Bassett regarding email

07/25/2023 DEB4 Conference with A. Tsukerman (CS) 0.40 1,320.00 528.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Date Initials Description Hours Rate Amount

07/25/2023 DEB4 Correspond with M. Tsukerman (CS) regarding HCHK documents 0.10 1,320.00 132.00 07/25/2023 DEB4 Conference with S. Placona (MSB) regarding HCHK documents 0.20 1,320.00 264.00 07/25/2023 ECS1 Analyze authority regarding service of

summary of findings regarding same for N.

07/25/2023 ECS1 Review correspondence with defense counsel regarding requests for production,

intervenors in HCHK adversary proceeding 0.20 1,015.00 203.00 07/25/2023 ECS1 Review proposed intervenors' motion to modify the TRO (.1); review local district court rules in connection with same (.1);

regarding same (.1) 0.30 1,015.00 304.50 07/25/2023 LAD4 Review/edit automatic stay arguments re: intervenors' motion and related issues 2.90 1,860.00 5,394.00 07/25/2023 Correspond with D. Barron on informant's

07/25/2023 Phone call with potential witness on his

07/25/2023 Phone call with informant on the GTV private placement, the farm loan program, and the proposed intervenors 0.60 815.00 489.00 07/25/2023 Prepare motion to authorize and compel discovery on proposed intervenors 2.50 815.00 2,037.50 Date Initials Description Hours Rate Amount 07/25/2023 NAB Correspond with W. Farmer, D. Barron regarding third party discovery requests to

intervene (.5); draft list of questions for same (.8); review complaint in connection with same (.4); analyze authority relating to

(.8); correspond with W. Farmer regarding

07/25/2023 NAB Review motion to modify TRO (.4); analyze response arguments (.4); correspond with L. Despins regarding same (.3) 1.10 1,625.00 1,787.50 07/25/2023 WCF Review, revise draft motion for expedited discovery regarding motion to intervene 0.60 1,235.00 741.00 07/26/2023 DEB4 Analyze motion to compel discovery 0.50 1,320.00 660.00 07/26/2023 DEB4 Correspond with N. Bassett regarding HCHK litigation strategy 0.30 1,320.00 396.00 07/26/2023 ECS1 Analyze case law regarding application of standards related to discovery in connection with intervention in adversary proceeding

compelling compliance with discovery (2.0); correspond with N. Bassett, W. Farmer, and P. Linsey (NPM) regarding same (.3); call with P. Linsey (NPM) regarding same (.1) 3.00 1,015.00 3,045.00 07/26/2023 Review draft motion to compel discovery

07/26/2023 Prepare summary of informant's email on

07/26/2023 Prepare draft rule 26(d)(1) motion to compel discovery on the proposed 2.10 815.00 1,711.50 Date Initials Description Hours Rate Amount 07/26/2023 NAB Review and revise draft motion to authorize

ancillary documents (.3) 2.20 1,625.00 3,575.00 07/26/2023 NAB Correspond with D. Barron regarding HCHK adversary proceeding strategy 0.30 1,625.00 487.50 07/26/2023 WCF Analyze authorities regarding expedited

non-parties (1.8); review, revise rule 26(d)(1) expedited discovery motion (1.3) 3.10 1,235.00 3,828.50 07/27/2023 LAD4 Review/edit motion to compel discovery of HCHK intervenors (1.40); long email to W. Farmer re: same (.50) 1.90 1,860.00 3,534.00 07/27/2023 Review Xuebing Wang's video and his

07/27/2023 Prepare summary of informant's email on HCHK entities and Kwok associates 1.00 815.00 815.00 07/27/2023 NAB Correspond with W. Farmer regarding discovery issues (.3); correspond with W.

revise written questions for deposition (.8); correspond with Y. Wang counsel regarding potential deposition (.2); correspond with Debtor's counsel regarding same (.1); review discovery authorization motion (.2) 1.80 1,625.00 2,925.00 07/27/2023 WCF Draft written deposition questions regarding Yvette Wang testimony 0.90 1,235.00 1,111.50 07/28/2023 DEB4 Analyze rule 9019 order (0.4); call with E.

with R. Jareck (CS) regarding same (0.1);

07/28/2023 ECS1 Review and compare issued rule 9019 order with proposed order (.1); correspond with D. Barron regarding same (.1); call with D. 0.30 1,015.00 304.50 Date Initials Description Hours Rate Amount 07/28/2023 LAD4 Review Judge Manning order re: discovery (.20); emails to/from N. Bassett, P. Linsey (NPM) re: same (.30) 0.50 1,860.00 930.00 07/28/2023 NAB Review order on motion to expedite discovery motion (.1); correspond with P. Linsey (NPM) regarding same (.1) 0.20 1,625.00 325.00 07/29/2023 DEB4 Correspond with J. Murray (DOJ) regarding discovery motion (0.1); correspond with N. Bassett and A. Luft regarding court's order

07/30/2023 Review emails and documents from

HCHK transactions 3.00 815.00 2,445.00 07/31/2023 DEB4 Review and comment on intervenor discovery issues 1.20 1,320.00 1,584.00 07/31/2023 KC27 Review order approving settlement 0.20 915.00 183.00 07/31/2023 AEL2 Correspond with D. Barron re: G Club

07/31/2023 Correspond with D. Barron on Tokyo informant and HCHK intervenors 0.40 815.00 326.00 07/31/2023 Correspond with informant in Tokyo on Shuai Guo and Japan Himalaya League, Inc. 0.30 815.00 244.50 Subtotal: B191 General Litigation 255.90 324,277.50

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

07/11/2023 AEL2 Travel to hearing on HCHK settlement motion in Bridgeport, CT from NY (Bill at

07/11/2023 AEL2 Travel back from hearing on HCHK settlement motion in Bridgeport, CT to NY (Bill at 1/2 rate) 1.90 812.50 1,543.75 07/18/2023 LAD4 Travel to/from courthouse for hearing (Bill

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

Subtotal: Description Travel to HCHK settlement hearing in Bridgeport, CT from NY (Bill at 1/2 rate)

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 29.40 1,860.00 54,684.00 LAD4 Luc A. Despins Partner 1.10 930.00 1,023.00 NAB Nicholas A. Bassett Partner 16.80 1,625.00 27,300.00 AB21 Alex Bongartz Of Counsel 0.50 1,625.00 812.50 AEL2 Luft, Avi E. Of Counsel 55.10 1,625.00 89,537.50 AEL2 Luft, Avi E. Of Counsel 5.30 812.50 4,306.25 DEB4 Douglass E. Barron Associate 52.40 1,320.00 69,168.00 WCF Will C. Farmer Associate 6.70 1,235.00 8,274.50 ECS1 Ezra C. Sutton Associate 49.00 1,015.00 49,735.00 KC27 Kristin Catalano Associate 21.40 915.00 19,581.00

JK21 Jocelyn Kuo Paralegal 3.30 540.00 1,782.00

Date Description Quantity Rate Amount 07/12/2023 Photocopy Charges 202.00 0.08 16.16 07/23/2023 Photocopy Charges 6,816.00 0.08 545.28

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2369640

07/13/2023 Postage/Express Mail - First Class - US; 19.60

07/13/2023 Postage/Express Mail - First Class - US; 4.14

07/24/2023 Postage/Express Mail - First Class - US; 50.25 07/24/2023 Postage/Express Mail - First Class - US; 58.80 07/24/2023 Postage/Express Mail - First Class - US; 58.80 07/24/2023 Postage/Express Mail - International; 58.80 07/24/2023 Postage/Express Mail - First Class - US; 9.80

07/31/2023 Search Fee - Companies Registry, Invoice# 20230731PT Dated 07/31/23, company search fee on 7 July 2023 for 1 company; requested by Ezra

07/31/2023 Articles and Publications - Javii Austin; 07/17/2023; International Transaction Fee - Corporate Summary Request for E. Sutton.; Merchant: International transaction 0.07 07/31/2023 Articles and Publications - Javii Austin; 07/17/2023; International Transaction Fee - Corporate Summary Request for E. Sutton.; Merchant: International transaction 0.35 07/31/2023 Articles and Publications - Javii Austin; 07/17/2023; Corporate Summary Request for E. Sutton.; Merchant: Small business bc; Orig Curr:

Luc Despins as Chapter 11 Trustee in the case of Ho Wan

07/31/2023 Articles and Publications - Javii Austin; 07/17/2023; Corporate Summary Request for E. Sutton.; Merchant: Small business bc; Orig Curr:

Total Costs incurred and advanced \$1,333.94

Total Balance Due - Due Upon Receipt \$356,551.69

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00015 Luc A. Despins

Legal fees for professional services for the period ending July 31, 2023 \$24,050.00

Total Balance Due - Due Upon Receipt \$25,092.24

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:Paul Hastings LLPLockbox 4803PO Box 894803Los Angeles, CA 90189-4803

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox* Case 22-50073r-Ddd 2256 Filed 10/16/23-1 Entered 10/2/6/23 22:05:06 24 Page 5206 of 486

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho September 7, 2023 Wan Kwok 200 Park Avenue New York, NY 10166