Guo Wengui / Miles Guo — criminal case · ECF #342-16

## UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

HO WAN KWOK,

Chapter 11

Case No: 22-50073 (JAM)

Debtor.

## DECLARATION OF AARON A. ROMNEY

I, AARON A ROMNEY, hereby declare:

1. I am a partner with the law firm Zeisler & Zeisler, P.C., counsel for Mei Guo ("Ms. Guo") and Hong Kong International Funds Investments (USA) LLC ("HKI Delaware"). I submit this Declaration pursuant to D.Conn.L.Civ.R. 37(a) in connection with Ms. Guo's Motion For Protective Order (the "Motion").

2. J The Motion seeks a protective order establishing the means by which Pacific Alliance Asia Opportunity Fund, L.P. ("PAX") may conduct the May 16, 2022, depositions of Ms. Guo and HKI Delaware in connection with PAX's Motion to Dismiss Chapter 11 Case or, In the Alternative, Partial Joinder to United States Trustee's Motion for an Order Directing the Appointment of a Chapter 11 Trustee (the "Motion to Dismiss") (Doc. No. 183). As detailed in the Motion, Ms. Guo seeks certain safeguards in order to ensure, to the extent possible, her physical safety and emotional security in connection with her upcoming depositions.

3. In a good faith effort to reach agreement on the means by which PAX would conduct the May 16, 2022 depositions of Ms. Guo and HKI Delaware to ensure her physical safety and emotional security, or at least narrow the issues presented to the Motion, on May 5 and 6, 2022, I conferred via telephone with Laura Aronsson and David Harbach, respectively, counsel for PAX.

4.

reach an agreement, in-whole or in-part, on the issues that are the subject of the Motion.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct.

Executed at Bridgeport, Connecticut on this 10th day of May, 2022.

Aaron A. Romney (ct28144) Zeisler & Zeisler PC 10 Middle Street Bridgeport, CT 06604 (203) 324-5473 aromney@zeislaw.com