In re: 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov 

HOLDWA VE TRADING LIMITED, Chapter 15 

Case No.: 

Debtor in a Foreign Proceeding. 

I - -------------

VERIFIED MOTION FOR ORDER OF RECOGNITION OF FOREIGN MAIN 

PROCEEDING PURSUANT TO §§ 1515 AND 1517 AND REQUEST FOR HEARING 

Nicholas Wood, Colin Diss, and Michael Leeds, the joint liquidators ("Joint Liquidators" 

or "Foreign Representatives"), move this Court for entry of an Order recognizing the creditors' 

voluntary liquidation ("UK Proceeding") of Holdwave Trading Limited ("Holdwave" or "Debtor") 

subject to the control or supervision of the High Court of Justice Business and Property Courts in 

Manchester Insolvency and Companies List (ChD) ("UK Court"), as a foreign main proceeding 

under 11 U.S.C. § 1517,1 granting related relief pursuant to§§ 1520 and 1521, and granting any 

additional relief which may be available under the Bankruptcy Code. The Foreign Representatives 

fmther request a hearing on the initial petition (ECF No. 1) ("Petition") and this Verified Motion 

no earlier than (21) days after the date the Court issues its notice of hearing but, in any event, "at 

the earliest possible time" thereafter. See Fed. R. Bankr. P. 2002(q); 11 U.S.C. § 1517(c). 

PRELIMINARY STATEMENT, JURISDICTION, & VENUE 

1. The Foreign Representatives file the Petition and this Verified Motion under § 

1504 to seek recognition of the UK Proceeding as a "foreign main proceeding," as defined in § 

1502(4). 

1 All statutory references shall be to Title 11 U.S.C. § 101 et seq. ("Bankruptcy Code"), unless 

otherwise specified. 

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2. The Petition and the Verified Motion are supported by the Declaration under 

penalty of perjury of Colin Diss ("Declaration") attached as Exhibit 1. The Declaration itself 

contains an exhibit referred to and incorporated herein. The Declaration also provides a summary 

of the UK Proceeding, a substantial fraud claim brought against Holdwave by creditors, and the 

conversion of the UK Proceeding to its current status as a creditors' voluntary liquidation subject 

to the supervision of the UK Court. 

3. A true and correct copy of the Order dated April 14, 2021 confirming the status of 

the liquidation and the Joint Liquidators' appointment in the same ("Liquidation and Appointment 

Order") is attached hereto as Exhibit 1-A.2 The Foreign Representatives took office as the joint 

liquidators for Holdwave pursuant to the resolution of creditors at a meeting duly convened for 

that purpose on February 10, 2021. Ex. 1 ,r 4. The Foreign Representatives have acted in the 

capacity as joint liquidators in the UK Proceeding continuously since Holdwave gave notice of 

their appointments to Companies House in the UK on February 11, 2021. Id. 

4. As required by Fed. R. Banla. P. 1007(a)(4), a Statement of Corporate Ownership, 

in conformity with Fed. R. Banla. P. 7007.1 is attached hereto as Exhibit 2. 

5. England and Wales is the center of main interests of the Debtor. Among other 

considerations: England and Wales is the location of the Debtor's registered address. See Ex. 1 ,r 

6. 3 The Foreign Representatives are unaware of any evidence that Holdwave conducted the 

administration of its affairs other than from its registered office or that it had any establishment or 

place of business outside England and Wales. 

2 Exhibit 1-A indicates the document attached to the Declaration as Exhibit A. 

3 See § 1516( c) ("In the absence of evidence to the contrary, the debtor's registered office, or 

habitual residence in the case of an individual, is presumed to be the center of the debtor's main 

interests."). 

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6. This Court has jurisdiction under 28 U.S.C. §§ 157 and 1334 and §§ I 09 and 150 l 

of the Bankruptcy Code. 

7. This is a core proceeding under 28 U.S.C. § 157(b)(2)(P). 

8. Venue is proper in this district under 28 U.S.C. § 1410. The Foreign 

Representatives have retained Sequor Law, P.A. ("Sequor Law") in this district and Sequor Law 

holds in its trust account in this District US$ 1,500 on behalf of and for the benefit of the Debtor, 

to which funds Sequor Law has no rights of setoff, charging lien, or similar right. See Ex. 1 ,r 24. 

BACKGROUND AND BASIS FOR RECOGNITION 

9. The Declaration sets forth in detail the background and basis for recognition and it 

is incorporated by reference as if fully set forth here. See Ex. 1. 

10. The Foreign Representatives have satisfied each of the requirements for recognition 

of the UK Proceeding under Chapter 15 of the Bankruptcy Code, as follows: 

(a) The Foreign Representatives qualify as "foreign representatives" as defined 

in 11 U.S.C. §101(24) because they are persons authorized in the UK Proceeding to 

administer the liquidation of the Debtor's assets and affairs, and to act as a representative 

of the UK Proceeding. 

(b) The UK Proceeding is a "foreign main proceeding" as defined in 11 U.S.C. 

§ 101(23) and 1502(4), because it is (i) pending in England and Wales, which is the 

Debtor's center of main interests; and (ii) a collective judicial proceeding under a law 

relating to insolvency or adjustment of debt in which proceeding the Debtor's assets and 

affairs are subject to the supervision of the UK Court for the purpose of liquidation. See 

Ex. 1 ,r,r 3, 5, 6, 26; Ex. 1-A. 

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( c) The Debtor meets the requirements of a "debtor" as defined in sections 

109(a), if applicable, and 1502 because the Debtor is the subject of a foreign proceeding 

and has assets in the United States, including property of the Debtor in trust with Sequor 

Law in the amount ofUS$1,500. See Ex. 1 ,r 24; Ex. 1-A. 

( d) This Verified Motion is accompanied by the Order of the UK Court, dated 

April 14, 2021, confirming the status of the liquidation and the Joint Liquidators' 

appointment in the UK Proceeding. See Ex. 1-A. 

(e) Additionally, the Declaration contains the list of all foreign proceedings, 

persons or entities that must be identified pursuant to 11 U.S.C. § 1515 and Fed. R. Bankr. 

P. 1007. See Ex. 1 ,r 31. 

RELIEF REQUESTED 

11. The Foreign Representatives seek an Order pursuant to§§ 105(a), 1507, 1517, 

1520, and 1521 of the Bankruptcy Code, substantially in the form of the Proposed Order, attached 

as Exhibit 3 hereto, granting the following relief: 

(a) Recognizing the UK Proceeding as a foreign main proceeding and the Foreign 

Representatives as the duly authorized foreign representatives of the Debtor; 

(b) Granting the relief allowable as of right upon recognition of a foreign main proceeding 

under § 1520 of the Bankruptcy Code; 

(c) Granting all available and appropriate relief under § 1521 of the Bankruptcy Code, 

including: 

(1) staying the commencement or continuation of any action or proceeding without 

the consent of the Foreign Representatives concerning rights, obligations, or 

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liabilities of the Debtor and the Debtor's bankruptcy estate, to the extent not 

stayed under§ 1520(a) of the Bankruptcy Code; 

(2) staying execution against the Debtor, to the extent not stayed under§ 1520(a); 

(3) suspending the right to transfer or otherwise dispose of any assets of the Debtor 

to the extent this right has not been suspended under § l 520(a); 

( 4) providing for the examination of witnesses, the taking of evidence, and the 

delivery of information concerning the assets, affairs, rights, obligations, or 

liability of the Debtor or the Debtor's estate under § 152l(a)(4), the Federal 

Rules of Bankruptcy Procedure, including Fed. R. Bank:r. P. 2004, and Local 

Rule 2004-1; 

(5) entrusting the administration or realization of all of the Debtor's assets within 

the territorial jurisdiction of the United States to the Foreign Representative; 

( 6) entrusting the distribution of all or part of the Debtor's assets located within the 

United States to the Foreign Representatives and finding that the assets of the 

creditors of the Debtor are sufficiently protected thereby; 

(7) requiring that other than a counterclaim to a suit brought by the Foreign 

Representatives, no person or entity may commence suit against the Foreign 

Representatives in any court, including this Court, in the United States without 

first obtaining leave of this Court; 

(8) otherwise granting comity to and giving full force and effect to the orders and 

documents attached to this Motion; and 

(9) granting the Foreign Representatives such other and further relief as this Court 

may deem just and proper. 

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CONCLUSION 

WHEREFORE, the Foreign Representatives respectfully request that this Court enter an 

Order, substantially in the form of the Proposed Order attached hereto as Exhibit 3 and grant such 

other relief as may be just and proper. 

28 U.S.C. § 1746 VERIFICATION 

I verify under penalty of perjury under the laws of the United States of America that the 

foregoing Verified Motion is true and correct. 

Dated: June 14, 2021 

Executed in London, Unit , ingdom on _!_f June, 2021 

d __J 

Colin Diss - as Joint Liquidator for Oceanroad Global 

Services Limited in the UK Proceeding 

Respectfully submitted, 

SEQUOR LAW, P.A. 

1111 Brickell A venue, Suite 1250 

Miami, Florida 33131 

Telephone: (305) 372-8282 

Facsimile: (305) 372-8202 

By: Isl Nyana Abreu Miller 

Edward H. Davis, Jr., Fla. Bar No. 704539 

edavis@sequorlaw.com 

Gregory S. Grossman, Fla. Bar No. 896667 

ggrossman@sequorlaw.com 

Nyana Abreu Miller, Fla. Bar No. 092903 

nmiller@sequorlaw.com 

Carolina Z. Goncalves, Fla. Bar No. 124570 

cgoncalves@seguorlaw.com 

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