UNITED STATES BANKRUPTCY COURT
`DISTRICT OF CONNECTICUT
`BRIDGEPORT DIVISION
`----------------------------------------------------------------
`In re:
`HO WAN KWOK, et al.,1
`Debtors.
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`Chapter 11
`Case No. 22-50073 (JAM)
`(Jointly Administered)
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`LUC A. DESPINS, CHAPTER 11
`TRUSTEE,
`Plaintiff,
`v.
`AVOIDANCE DEFENDANTS,
`Defendants.
`(caption continues on next page)
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`Adv. Proceeding Nos. 24-05005, 24-05006,
`24-05008, 24-05009, 24-05010, 24-05011,
`24-05012, 24-05013, 24-05014, 24-05015,
`24-05016, 24-05017, 24-05018, 24-05019,
`24-05020, 24-05021, 24-05022, 24-05023,
`24-05024, 24-05025, 24-05026, 24-05027,
`24-05028, 24-05029, 24-05030, 24-05031,
`24-05032, 24-05033, 24-05035, 24-05036,
`24-05037, 24-05038, 24-05039, 24-05040,
`24-05041, 24-05042, 24-05043, 24-05044,
`24-05045, 24-05046, 24-05047, 24-05048,
`24-05049, 24-05050, 24-05051, 24-05052,
`24-05053, 24-05054, 24-05055, 24-05056,
`24-05057, 24-05058, 24-05059, 24-05060,
`24-05061, 24-05062, 24-05063, 24-05064,
`24-05065, 24-05066, 24-05067, 24-05068,
`24-05069, 24-05070, 24-05071, 24-05072,
`24-05073, 24-05074, 24-05075, 24-05076,
`24-05077, 24-05078, 24-05079, 24-05080,
`24-05081, 24-05082, 24-05084, 24-05085,
`24-05086, 24-05087, 24-05088, 24-05089,
`24-05090, 24-05091, 24-05092, 24-05093,
`24-05094, 24-05095, 24-05096, 24-05097,
`24-05098, 24-05099, 24-05100, 24-05101,
`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 the 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).
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 1 of 28
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`24-05102, 24-05103, 24-05104, 24-05105,
`24-05106, 24-05107, 24-05108, 24-05109,
`24-05110, 24-05111, 24-05112, 24-05113,
`24-05114, 24-05115, 24-05116, 24-05117,
`24-05118, 24-05119, 24-05120, 24-05121,
`24-05122, 24-05123, 24-05124, 24-05125,
`24-05126, 24-05127, 24-05128, 24-05129,
`24-05130, 24-05131, 24-05133, 24-05134,
`24-05135, 24-05136, 24-05137, 24-05138,
`24-05139, 24-05140, 24-05141, 24-05142,
`24-05143, 24-05144, 24-05145, 24-05146,
`24-05147, 24-05148, 24-05149, 24-05150,
`24-05151, 24-05152, 24-05153, 24-05154,
`24-05155, 24-05156, 24-05157, 24-05159,
`24-05160, 24-05161, 24-05162, 24-05163,
`24-05164, 24-05165, 24-05166, 24-05167,
`24-05168, 24-05169, 24-05170, 24-05171,
`24-05172, 24-05173, 24-05174, 24-05175,
`24-05176, 24-05177, 24-05178, 24-05179,
`24-05180, 24-05181, 24-05182, 24-05184,
`24-05185, 24-05186, 24-05188, 24-05189,
`24-05190, 24-05191, 24-05192, 24-05193,
`24-05195, 24-05196, 24-05197, 24-05198,
`24-05199, 24-05200, 24-05201, 24-05202,
`24-05203, 24-05204, 24-05205, 24-05206,
`24-05207, 24-05208, 24-05209, 24-05210,
`24-05211, 24-05212, 24-05214, 24-05215,
`24-05216, 24-05217, 24-05218, 24-05219,
`24-05220, 24-05221, 24-05222, 24-05223,
`24-05224, 24-05225, 24-05226, 24-05227,
`24-05228, 24-05229, 24-05230, 24-05231,
`24-05232, 24-05233, 24-05234, 24-05235,
`24-05236, 24-05237, 24-05238, 24-05239,
`24-05240, 24-05241, 24-05242, 24-05243,
`24-05244, 24-05245, 24-05246, 24-05247,
`24-05248, 24-05250, 24-05251, 24-05252,
`24-05253, 24-05254, 24-05255, 24-05256,
`24-05257, 24-05258, 24-05259, 24-05260,
`24-05261, 24-05262, 24-05263, 24-05264,
`24-05265, 24-05266, 24-05267, 24-05268,
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 2 of 28
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`24-05269, 24-05270, 24-05271, 24-05272,
`24-05274, 24-05275, 24-05276, 24-05279,
`24-05280, 24-05282, 24-05286, 24-05287,
`24-05288, 24-05289, 24-05290, 24-05291,
`24-05292, 24-05293, 24-05294, 24-05295,
`24-05296, 24-05297, 24-05298, 24-05299,
`24-05300, 24-05301, 24-05302, 24-05303,
`24-05304, 24-05305, 24-05306, 24-05307,
`24-05308, 24-05309, 24-05310, 24-05313,
`24-05315, 24-05316, 24-05317, 25-05003,
`25-05004, 25-05005, 25-05006, 25-05007,
`25-05008, 25-05009, 25-05010, 25-05011,
`25-05012, 25-05013, 25-05014, 25-05015,
`25-05016, 25-05017, 25-05018, 25-05019,
`25-05020, 25-05021, 25-05022, 25-05023,
`25-05024, 25-05025, 25-05026, 25-05027,
`25-05028, 25-05029, 25-05030, 25-05031,
`25-05032, 25-05033, 25-05034, 25-05035,
`25-05036, 25-05037, 25-05038, 25-05039,
`25-05040, 25-05041, 25-05042, 25-05043,
`25-05044, 25-05045, 25-05046, 25-05047,
`25-05048, 25-05049, 25-05050, 25-05051,
`25-05052, 25-05057, 25-05058, 25-05059,
`25-05061, 25-05067, 25-05068, 25-05069,
`25-05070, 25-05071, 25-05072, 25-05073,
`25-05074, 25-05075, 25-05076, 25-05077,
`25-05078, 25-05079, 25-05080, 25-05081,
`25-05082, 25-05083, 25-05084, 25-05085,
`25-05086, 25-05087, 25-05088, 25-05089,
`25-05090, 25-05091, 25-05092, 25-05093,
`25-05094, 25-05095, 25-05096, 25-05097,
`25-05098, 25-05099, 25-05100, 25-05101,
`25-05102, 25-05103, 25-05104, 25-05105
`NOTICE OF ENTRY OF ORDER: (A) GRANTING IN PART CHAPTER 11
`TRUSTEE’S MOTION FOR ENTRY OF ORDER AMENDING
`AVOIDANCE AND MEDIATION PROCEDURES; AND
`(B) ENTERING AVOIDANCE ACTION PRETRIAL ORDER
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 3 of 28
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`4
`PLEASE TAKE NOTICE: that the Court’sOrder: (A) Granting in Part Chapter 11
`Trustee’s Motion for Entry of Order Amending Avoidance and Mediation Procedures; and (B)
`Entering Avoidance Actions Pretrial Order [Main Case ECF No. 4828] (the “Order”) dated
`November 6, 2025, appended hereto as Exhibit A, has entered, which Order is binding in this
`adversary proceeding as if it were entered as a separate order herein.
`Dated: November 7, 2025 LUC A. DESPINS,
`New Haven, Connecticut CHAPTER 11 TRUSTEE,
`By: /s/ Patrick R. Linsey
`Patrick R. Linsey (ct29437)
`NEUBERT, PEPE & MONTEITH, P.C.
`195 Church St., 13th Fl.
`New Haven, CT 06510
`Tel: (203) 781-2847
`Fax: (203) 821-2008
`plinsey@npmlaw.com
`Counsel for the Chapter 11 Trustee
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 4 of 28
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`EXHIBIT A
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 5 of 28
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`UNITED STATES BANKRUPTCY COURT
`DISTRICT OF CONNECTICUT
`
`
`In re:
`
` HO WAN KWOK, et al.,
`
` Debtors.
`1
`
`
` Chapter 11
` Case No. 22-50073 (JAM)
` (Jointly Administered)
`
` Re: ECF No. 4628
`
`
`ORDER: (A) GRANTING IN PART CHAPTER 11 TRUSTEE’S MOTION FOR
`ENTRY OF ORDER AMENDING AVO I DANCE AND MEDIATION PROCEDURES;
`AND (B) ENTERING A VO
` IDANCE ACTIONS PRETRIAL ORDER
`
`I. The Chapter 11 cases and the avoidan ce actions
`On February 15, 2022, Mr. Ho Wan Kwok (the “Individual Debtor”) filed a voluntary
`Chapter 11 petition in this Court. On July 8, 2022, Mr. Luc A. Despins, was appointed as
`Chapter 11 trustee (the “Trustee”) for the bankruptcy estate of the Individual Debtor. After the
`Trustee was appointed in the Individual Debtor’s case, the Court ordered the joint administration
`of the Individual Debtor’s case with the Chapter 11 cases of two related corporate entities,
`Genever Holdings LLC and Genever Holdings Corporation (the “jointly administered Chapter 11
`cases”). Before reviewing the relief the Trustee is seeking with regard to existing orders in these
`jointly administered Chapter 11 cases, it is important to note the procedural history of the related
`adversary proceedings.
`
`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 the 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).
`Case 22-50073 Doc 4828 Filed 11/06/25 Entered 11/06/25 15:10:19 Page 1 of 23
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 6 of 28
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`2
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`Beginning on February 1, 2024, the Trustee commenced almost 400 adversary
`proceedings seeking to avoid certain transfers he alleges are property of the Individual Debtor’s
`estate (collectively, the “Avoidance Actions”). All the complaints in the Avoidance Actions
`assert claims against hundreds of defendants (collectively, the “Avoidance Action Defendants”)
`under sections 544, 547, 548, 549, and/or 550 of the Bankruptcy Code and analogous claims
`under applicable state law. Before and after the commencement of the Avoidance Actions, the
`Trustee filed several motions to establish procedures for the management and mediation of the
`Avoidance Actions. To date, the following orders have governed the management and mediation
`of the Avoidance Actions:
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`1. The Avoidance Action Procedures Order dated February 7, 2024 (ECF No. 2578);
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`2. The Order Directing Parties to Mediation, Appointing the Honorable James J. Tancredi as
`Mediator, and Amending Avoidance Action Procedures Order dated May 2, 2024 (the
`“Litigation Procedures Order,” ECF No. 3163). Among other things, the Litigation
`Procedures Order provides: (i) in paragraphs 2(e)(i) and 2(e)(ii), a full or partial stay of
`the Trustee’s claims applicable to specific defendants in Avoidance Actions listed in
`Exhibits 3-A and 3-B; and (ii) in paragraph 2(j)(iii), an automatic referral to mediation of
`the Trustee’ s claims against a specific defendant who filed an appearance in an
`Avoidance Action prior to the deadline to respond to a complaint and a stay of such
`claims during mediation;
`
`3. The Order Amending the Litigation Procedures Order dated August 28, 2024 (the “Pre-
`Litigation/Pre-Appearance Mediation Procedures Order,” ECF No. 3465). The Pre-
`Litigation/Pre-Appearance Mediation Procedures Order amended the Litigation
`Procedures Order to allow the Trustee to mediate with parties subject to possible
`avoidance claims prior to commencing an Avoidance Action; and
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`4. The Order Further Amending the Litigation Procedures Order dated November 5, 2024
`(the “Temporary Stay of Discovery Order,” ECF No. 3659) which temporarily stayed all
`discovery in Avoidance Actions pending the Court’s resolution of several dispositive
`motions.
`
`The orders set forth above are collectively referred to as the “Procedures Orders.”
`Case 22-50073 Doc 4828 Filed 11/06/25 Entered 11/06/25 15:10:19 Page 2 of 23
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 7 of 28
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`After undertaking a Joint Brief process2 requested by numerous defendants in certain
`Avoidance Actions, the Court issued several decisions between March and May of 2025 denying
`more than fifty (50) motions to dismiss and motions for judgment on the pleadings filed by the
`Joint Brief defendants and other defendants. Following those decisions, a Status Conference was
`held in the jointly administered Chapter 11 cases on June 10, 2025. Several issues were
`discussed during the Status Conference, including when each defendant whose motion was
`denied would file an answer to the Trustee’s complaint. In addition to discussing an answer date,
`the Trustee’s counsel informed the Court that the Trustee was not certain the automatic referral of
`Avoidance Actions to mediation in the Procedures Orders should continue. He then mentioned
`the Trustee would likely file a motion to further amend the Procedures Orders, would review any
`proposed amendments to the Procedures Orders with the defendants whose motions were denied
`and with those who filed appearances in Avoidance Actions or appeared at the Status Conference,
`and would provide those defendants with a draft of any proposed amendments to the Procedures
`Orders before filing such a motion. Three days after the Status Conference, the Trustee served a
`draft of proposed amendments to the Procedures Orders upon counsel for those defendants.
`II. The Amended Procedures Motion
`On August 28, 2025, following months of discussions with counsel, the Trustee filed a
`motion to supplement, amend, and supersede the Procedures Orders (the “Amended Procedures
`Motion,” ECF No. 4628). The Amended Procedures Motion set forth proposed discovery
`procedures, including when discovery would commence and how discovery would be conducted.
`A hearing on the Amended Procedures Motion was scheduled to be held on October 21, 2025,
`with responses and objections to the Amended Procedures Motion to be filed by October 10,
`
`2 See Joint Briefing Order, ECF No. 3577.
`Case 22-50073 Doc 4828 Filed 11/06/25 Entered 11/06/25 15:10:19 Page 3 of 23
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 8 of 28
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`2025. (ECF No. 4631.) Certain defendants timely filed responses or objections to the Amended
`Procedures Motion, and other defendants joined the responses or objections to the Amended
`Procedures Motion (collectively, the “Objecting Defendants”).3 On October 17, 2025, the
`Trustee filed a reply to the Objecting Defendants’ responses and objections. (ECF No. 4749.)
`On October 21, 2025, an initial hearing on the Amended Procedures Motion was held.
`For the reasons stated on the record, the hearing was continued to October 23, 2025. Prior to the
`continued hearing held on October 23, 2025, and in response to comments made by the Court
`during the initial hearing, the Trustee provided revised proposed pretrial procedures to the
`Objecting Defendants. During the October 23
`rd continued hearing, the Court heard from many of
`the Objecting Defendants, agreed to allow the Objecting Defendants to submit a counterproposal
`to the Trustee’s proposed pretrial procedures by October 29, 2025, and again continued the
`hearing to November 3, 2025.
`Prior to the November 3
`rd continued hearing, the Trustee and the Objecting Defendants
`discussed the proposed pretrial procedures and the Objecting Defendants’ counterproposals and
`objections.4 During the continued hearing, the Trustee and several of the Objecting Defendants
`advanced their respective arguments regarding the proposed pretrial procedures, noting a general
`agreement as to the framework of a pretrial order, but a lack of agreement on specific issues such
`as the timing and scope of discovery. At the conclusion of the continued hearing, the Court took
`the Amended Procedures Motion under advisement.
`The Individual Debtor’s case has been pending since February 15, 2022. The Avoidance
`Actions have been pending since February 2024. However, discovery has not begun in any of
`
`3 A list of the names of the Objecting Defendants and the responses filed to the Amended
`Procedures Motion is attached as Appendix A.
`4 See ECF Nos. 4790, 4791, 4794, 4795, 4796, 4798, 4799, 4811.
`Case 22-50073 Doc 4828 Filed 11/06/25 Entered 11/06/25 15:10:19 Page 4 of 23
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 9 of 28
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`5
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`the Avoidance Actions for several reasons, including because of the stay in effect while parties
`have attempted to mediate a resolution of certain Avoidance Actions. As the Court and many
`parties noted during the hearings, the litigation and mediation stay imposed by the Procedures
`Orders should no longer be in effect and parties should move forward with litigation in the
`Avoidance Actions.
`In light of all these issues, including the sheer volume of Avoidance Actions and the
`passage of time since the Avoidance Actions were filed, the Court agrees the Procedures Orders
`should be amended and discovery should commence. To that end, the Court has reviewed the
`record in these jointly administered Chapter 11 cases, the record in the Avoidance Actions, the
`Procedures Orders, the Amended Procedures Motion, the responses, replies, and
`counterproposals to the proposed pretrial procedures, and considered the arguments advanced by
`the parties during the hearings held on October 21, October 23, and November 3, 2025. While
`the Court appreciates the efforts of the Trustee and the Objecting Defendants in resolving many
`disagreements about the proposed pretrial procedures, the parties have not been able to reach a
`consensus on proposed pretrial procedures. Because it is necessary and appropriate to efficiently
`and effectively administer and manage the hundreds of Avoidance Actions, the Court will grant
`the Amended Procedures Motion in part and will establish pretrial procedures which shall apply
`in all Avoidance Actions and to all Avoidance Action Defendants.
`Accordingly, to ensure the just, speedy, and inexpensive determination of every
`Avoidance Action, and in accordance with Dietz v. Bouldin, 579 U.S. 40, 45 (2016), In re World
`Trade Ctr. Disaster Site Litig., 722 F.3d 483, 487 (2d Cir. 2013), Federal Rules of Civil
`Procedure 1, 16, 26, and Fed. R. Bankr. P, 1001, 7016, and 7026; it is hereby
`Case 22-50073 Doc 4828 Filed 11/06/25 Entered 11/06/25 15:10:19 Page 5 of 23
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 10 of 28
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`6
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`ORDERED: The Amended Procedures Motion is GRANTED IN PART. The
`Procedures Orders are amended as set forth herein. On or before November 7, 2025, the Trustee
`shall file this Order in all Avoidance Actions that are not dismissed, closed, or reported as settled
`or resolved. This Order is binding in all the Avoidance Actions as if this Order was entered as a
`separate Order in each of the Avoidance Actions; and it is further
`ORDERED: As ordered on the record during the continued hearing held on November
`3, 2025, the full and partial stay of claims in paragraphs 2(e)(i) and 2(e)(ii) of the Litigation
`Procedures Order applicable to certain defendants listed in Exhibits 3-A and 3-B, and the
`mediation stay in paragraph 2(j)(iii) of the Litigation Procedures Order, are lifted and no longer
`in effect; and it is further
`ORDERED: The provision for the automatic Mediation Referral of Avoidance Actions
`in paragraph 2(j)(i) of the Litigation Procedures Order is no longer in effect. To the extent that
`the provisions of the Litigation Procedures Order and the Pre-Litigation/Pre-Appearance
`Mediation Procedures Order do not conflict with the provisions of this Order, the following
`provisions of the Litigation Procedures Order and the Pre-Litigation/Pre-Appearance Mediation
`Procedures Order survive the provisions of this Order: (i) the provisions regarding the
`appointment of the Mediator; and (ii) the provisions governing Mediation Proceedings.
`Mediation Proceedings can and should continue by agreement of the parties. However,
`Mediation Proceedings can be terminated by either party or by the Mediator upon written notice
`to the parties to the specific mediation; and it is further
`
`Case 22-50073 Doc 4828 Filed 11/06/25 Entered 11/06/25 15:10:19 Page 6 of 23
`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 11 of 28
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`7
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`ORDERED: The following Pretrial Procedures are established and shall apply in all
`Avoidance Actions and to all Avoidance Action Defendants unless the Court orders otherwise:
`A VOIDANCE ACTIONS PRETRIAL ORDER
`I. TRUSTEE’S MOTION TO APPLY PRETRIAL PROCEDURES
`TO OMNIBUS ALTER EGO ACTIONS5
`
`On or before November 14, 2025, the Trustee shall file a motion seeking approval of
`similar pretrial procedures in the Omnibus Alter Ego Actions to request that those actions may be
`litigated and tried under Fed. R. Civ. P. 42 to avoid duplication of efforts and redundant
`proceedings. The Court will determine which trial proceedings may be sequenced and/or
`consolidated as appropriate, including under Fed. R. Civ. P. 42 (made applicable by Fed. R.
`Bankr. P. 7042), and will consider the Trustee’s request to give priority to first adjudicating
`claims involving postpetition transfers and transfers involving entities that have been deemed to
`be beneficially owned by the Individual Debtor and/or are the Individual Debtor’s alter egos by
`existing judgments.
`II. DEADLINE F
` OR DEFENDANTS’ ANSWERS AND RESPONSES TO PENDING
`MOTIONS TO AMEND COMPLAINTS
`
`A. Answer dea dline for Objecting Defendants. The Objecting Defendants shall file
`an Answer to the Complaint/Amended Complaint filed against it on or before November 14,
`2025, unless: (i) an answer has already been filed; (ii) an agreed to/stipulated extension of time
`exists; (iii) a motion to amend the complaint is pending; or (iv) the Court has ordered otherwise.
`No extension of the deadline set forth herein will be granted without further order of the Court.
`
`5 The adversary proceedings Despins v. ACA Cap. Grp. Ltd., et al., Adv. Pro. No. 24-05249 and
`AA Glo. Ventures Ltd, et al., Adv. Pro. No. 24-05322 are collectively the “Omnibus Alter Ego
`Actions.”
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`Case 24-05291 Doc 15 Filed 11/07/25 Entered 11/07/25 10:47:38 Page 12 of 28
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`8
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`B. Answer de adline for all other Avoidance Action Defendants. All other Avoidance
`Action Defendants, including Avoidance Action Defendants whose claims against them have
`been stayed under ¶¶2(e)(i) and (e)(ii) or 2(j)(iii) of the Litigation Procedures Order, shall file an
`Answer to the Complaint/Amended Complaint filed against it on or before December 15, 2025,
`unless (i) an answer has already been filed; (ii) an agreed to/stipulated extension of time exists;
`(iii) a motion to amend the complaint is pending; or (iv) the Court has ordered otherwise. No
`extension of the deadline set forth herein will be granted without further order of the Court.
`C. Response dea dline to pending motions to amend complaint and answer deadline
`to Amended Complaint if motion is granted. The deadline for all Avoidance Action
`Defendants to file responses to pending motions to amend complaint (“Motion to Amend”) is
`December 15, 2025. The Court will determine if a hearing on a Motion to Amend is necessary
`or if it can decide a Motion to Amend on the submission of the parties. No extension of the
`deadline set forth herein will be granted without further order of the Court.
`If a Motion to Amend is granted or resolved, the deadline for the Avoidance Action
`Def
`endant to file an answer to the Amended Complaint will be fourteen (14) days after the
`motion is granted or resolved, unless otherwise ordered by the Court. No extension of the
`deadline set forth herein will be granted without further order of the Court.
`III. NO STAY OF CONSTRUCTIVE FRAUDULENT TRANSFER CLAIMS
`Litigation of any constructive fraudulent transfer claims under section 548(a)(1)(B) of the
`Bankruptcy Code or section 544(b) of the Bankruptcy Code and applicable state law shall not be
`stayed.
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`IV. INITIAL DISCLOSURES
`A. Deadline for Objecting Defendants. To the extent that it has not already done so,
`each Objecting Defendant shall make the initial disclosures required by Fed. R. Civ. P. 26(a)(1)
`on or before November 21, 2025. No extension of the deadline set forth herein will be granted
`without further order of the Court.
`B. Deadline for remaining Avoidance Action Defendants. T o the extent that it has not
`already done so, each remaining Avoidance Action Defendant shall make the initial disclosures
`required by Fed. R. Civ. P. 26 (a)(1) on or before December 15, 2025. No extension of the
`deadline set forth herein will be granted without further order of the Court.
`C. Deadline for Trustee. The Trustee will satisfy his obligations under Fed. R. Civ. P.
`26(a)(1) by population of documents and evidentiary material into the electronic discovery
`depository (the “Depository”) on or before January 2, 2026, as set forth below. No extension of
`the deadline set forth herein will be granted without further order of the Court.
`D. Good faith requirement. All in itial disclosures shall be made in good faith and in
`the exercise of reasonable diligence and shall be supplemented and corrected pursuant to and in
`accordance with Fed. R. Civ. P. 26(e), as made applicable by Fed. R. Bankr. P. 7026.
`V. DISCOVERY S CHEDULE
`A. Data Rooms. The Trustee shall produce docume nts through the Depository
`organized into data rooms (the “Data Rooms”) subject to the Trustee’s reservations that a vast
`majority of the documents were produced to the Trustee by third parties. By January 2, 2026,
`the Trustee shall create and populate the Depository compromised of Data Rooms containing
`folders organized by source and with documents related to (i) all alter ego and/or beneficial
`owner entities involved in alleged avoidable transfers; (ii) any defendant who has filed an
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`appearance in the Avoidance Actions; and (iii) all allegations in Avoidance Complaints. No
`extension of the deadline set forth herein will be granted without further order of the Court.
`The Trustee makes no representations as to the accuracy or authenticity of such
`documents, and the inclusion of such documents does not constitute an admission or basis to
`argue such documents are relevant or admissible or constitute an admission of any fact.
`The Depository shall only be accessed by counsel and Avoidance Action Defendants that
`have signed the operative Protective Order/Addendum.6 The Protective Order/Addendum shall
`otherwise apply in all discovery proceedings under this Order.
`B. Written Discovery.
`1. Requests for Production of Documents.
`a. No Requests for Production shall be served on Trustee. In accordance with
`the provisions requiring the Trustee to create and populate the Data Rooms, no requests for
`production of documents shall be served on the Trustee without order of the Court.
`b. Deadline fo
` r Trustee to serve Requests for Production. Unless a default or
`default judgment has entered, or a dismissal or settlement of an Avoidance Action has occurred,
`the Trustee shall serve Requests for Production of Documents, if any, on the Avoidance Action
`Defendants on or before February 9, 2026. No extension of the deadline set forth herein will be
`granted without further order of the Court.
`c. Response and objection deadline for Avoidance Action Defendants. All
`responses and objections to requests for production shall be served on or before March 11, 2026
`provided that the date to commence production may be rolling based on a schedule agreed to by
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`6 The Protective Order/Addendum refers to the Protective Order (ECF No. 923), and the
`amended/stipulated Addendum to the Protective Order (ECF Nos. 2460, 3264, 4448).
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`the Trustee and a particular Avoidance Action Defendant that does not exceed any deadlines set
`forth in this Order.
`d. Draft Data Room Depository Requests for Production. To the extent
`Avoidance Action Defendants believe relevant documents and information are not available or
`readily identifiable in the Depository, Avoidance Action Defendants shall serve a draft request
`for production identifying such documents and information and promptly meet and confer with
`the Trustee to determine whether such documents and information exist in the Trustee’s
`possession, custody, or control or are identifiable in the Depository. If the Parties cannot resolve
`this issue, Avoidance Action Defendants may seek relief from the Court to order production of
`the documents and information identified in the draft request for production into the Depository.
`The production of documents or information shall neither constitute nor evidence waiver
`of at
`torney-client privilege or work product doctrine. At the close of discovery, the Trustee and
`the Avoidance Action Defendants shall meet and confer as to the authentication of documents by
`stipulation.
`2. Interrogatories.
`a. Deadline for Trustee to serve Interrogatories. Unless a default or default
`judgment has entered, or a dismissal or settlement of an Avoidance Action has occurred, the
`Trustee shall serve, if any, no more than 25 interrogatories against each Avoidance Action
`Defendant on or before February 9, 2026. No extension of the deadline set forth herein will be
`granted without further order of the Court.
`b. Deadline for Av oidance Action Defendants to serve Interrogatories. As to
`issues regarding alter ego and/or beneficial owner entities involved in alleged avoidable
`transfers, all Avoidance Action Defendants as to which a particular entity is relevant shall
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`cooperate to serve no more than 25 join t interrogatories on the Trustee on or before February 9,
`2026. As to issues in its particular Avoidance Action, each Avoidance Action Defendant may
`serve no more than 10 interrogatories on the Trustee on or before February 9, 2026. No
`extensions of the deadlines set forth herein will be granted without further order of the Court.
`c. Response and Objection deadline. A ll responses and objections to
`interrogatories shall be served on or before March 11, 2026. Any Avoidance Action Defendant
`may seek an increase in the number of interrogatory requests by agreement or order of the Court.
`No extension of the deadline set forth herein will be granted without further order of the Court.
`3. Requests for Admission.
`a. Deadline for Trustee to serve Requests for Admission. Unless a default or
`default judgment has entered, or a dismissal or settlement of an Avoidance Action has occurred,
`on or before February 9, 2026, the Trustee shall serve, if any, no more than 25 requests for
`admission against each Avoidance Action Defendant. No extension of the deadline set forth
`herein will be granted without further order of the Court.
`b. Deadline for Avoidance Action Defendants to serve Requests for
`Admission. As to issues regarding alter ego and/or beneficial owner entities involved in alleged
`avoidable transfers, all Avoidance Action Defendants as to which a particular entity is relevant
`shall cooperate to serve no more than 25 joint requests for admission on the Trustee on or before
`February 9, 2026. As to all other issues in its particular Avoidance Action, each Avoidance
`Action Defendant may serve no more than 10 requests for admissions on the Trustee on or before
`February 9, 2026. No extensions of the deadlines set forth herein will be granted without
`further order of the Court.
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`c. Responses and Objection de adline. All responses and objections to requests
`for admission shall be served on or before March 11, 2026. Any Avoidance Action Defendant
`may seek an increase in the number of requests for admission by agreement or order of the
`Court. No extension of the deadline set forth herein will be granted without further order of the
`Court.
`VI. PRIVILEGE LOGS
`Th
`e Trustee will serve in the initial instance a categorical privilege log identifying, for
`each category of withheld documents, (i) general parties to such documents or communications
`(e.g., the Individual Debtor and his bankruptcy counsel at a particular law firm); (ii) the general
`subject matter of the withheld documents (e.g., legal advice related to