I would say ... no, no, no ... on those foot positions.
Once you get to the extension, having the attacker facing 9:00 o'clock will mess everything up.
I checked back of the 'Kenpo Kards', and this source has the feet of both defender and attacker facing 12:00. It does show the attack more from 4:30 than 3:00. But, I still think it needs to be a close attack ~ for a short range response.
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