In re Kwok — 2d Cir. (Sep 23, 2026)
The Second Circuit hears In re Kwok. Ho Wan Kwok filed for Chapter 11 bankruptcy in 2022. Greenwich Land, a Delaware company nominally owned by Hing Chi Ngok, held 373 Taconic Road, a house Kwok used as his bankruptcy mailing address. Trustee Luc Despins said Kwok's associates funded and ran the company while Ngok knew little about its finances or operations. The bankruptcy court found the company was Kwok's alter ego and its assets belonged to the estate; the district court affirmed. This appeal asks whether those courts improperly resolved factual and evidentiary disputes, or whether the undisputed record showed Kwok's control. Two days after the argument, the Second Circuit affirmed, finding any possible law-of-the-case error harmless and the evidence of Kwok's control overwhelming and uncontroverted. Stephen Kindseth of Zeisler and Zeisler represents Greenwich Land and Hing Chi Ngok. He will argue that the bankruptcy judge discounted evidence of Ngok's ownership and improperly resolved facts and evidentiary questions.
In re Kwok (No. 25-2742) — U.S. Court of Appeals for the Second Circuit, argued September 23, 2026.
- 0:00Introduction
- 2:16Reverse veil piercing
- 3:40Law of the case
- 10:44Nicholas Bassett — Chapter 11 trustee Luc Despins