{"id":"court_2cir_26-1626_dkt_1","court":"2Cir","case_no":"","doc_number":null,"sub_number":null,"doc_type":"DOC","filed_date":null,"title":"2Cir ECF 26-1626_dkt_1","summary_zh":"职务执行令（mandamus）申请——美国诉 Ho Wan Kwok（郭文贵/Guo Wengui/Miles Guo）案第二巡回上诉法院26-1626号 ECF #1（2026年6月12日立案,信函署期6月9日）。申请人“Anna”以第三方pro se身份,依据21 U.S.C. §853(n)、联邦刑事诉讼规则32.2(c)/49.1及全令状法（All Writs Act）请求二巡下令SDNY一审法院将其此前提交、屡遭拒绝登记的《传唤Luc Despins及喜马拉雅联盟/农场关键人员动议（主张853(n)权利）》（2026年5月22日提交）正式入卷并就实体问题作出裁决。申请人自称为G系列合法投资人,质疑检方“受害人/共谋人”二分归类框架及破产受托人Luc Despins未经完整举证的“另我”（alter ego）认定并据此没收其资金,并指控“凤凰农场”CEO 魏立宏向中国当局传输投资人信息、导致证人受胁迫作证。","summary_en":"Petition for a writ of mandamus — United States v. Ho Wan Kwok (Miles Guo / Guo Wengui), Second Circuit No. 26-1626, ECF #1 (docketed June 12, 2026; cover letter dated June 9, 2026). Pro se third-party petitioner \"Anna\" invokes 21 U.S.C. § 853(n), Fed. R. Crim. P. 32.2(c) and 49.1, and the All Writs Act, asking the Second Circuit to order the SDNY district court to docket her repeatedly-rejected \"Motion to Subpoena Luc Despins and Key Himalaya Alliance & Farm Personnel\" (filed May 22, 2026) and rule on its merits. She claims to be a bona fide G-Series investor entitled to an ancillary forfeiture proceeding, disputes the government's victim/co-conspirator classification framework and Chapter 11 Trustee Luc Despins's unadjudicated \"alter ego\" theory used to seize the funds, and alleges that Phoenix Farm CEO Wei Lihong transmitted investor records to PRC authorities, coercing witness testimony.","body_en":"Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 1 of 61\nredar-kct\nDate: June 9\", 2026\nFrom:\nAddress:\nTelephone:\nEmail:\nTo: Clerk of Court\nUnited States Court of Appeals\n2ND Circuit\n40 Foley Square New York, NY 10007\nRe: Petition for Writ of Mandamus\nPetitioner: Anna\nCase: United States v. Kwok, et al.1 :23-CR-0011 S(AT)\nDear Clerk of the 2\"' Circuit Court,\nEnclosed please find a Petition for Writ of Mandamus, filed by Ann~ a Pro Se Petitioner in\nUnited States v. Kwok, et al 1 :23-CR-0011 S(AT), under 21 U.S.C. § 853(n), Fed. R. Crim. P. 32.2(c), Fed. R.\nCrim. P. 49.1, and 28 U.S.C. § 1651 (a).\nEnclosed are:\nAFFIDAVIT FOR PERMISSION IN FORMA PAUPERIS\nPetition for Writ of Mandamus\nExhibit A-\"Motion to Subpoena Luc Despins and Key Himalaya Alliance & Farm Personnel; Evidentiary\nHearing, & Asserting 853(n) Rights, Privacy and Declaration\", filed with SDNY District Court on 5/22/2026\nExhibit B - Proofs that the 5/22/26 Motion was sent to the SDNY District Court\nExhibit C - Proof of email request to the District Court for Docketing, dated 5/29/2026\nExhibit D -Proof of email request to the District Court for Docketing, dated 6/2/2026\nExhibit E -Proof of email request \"Motion to Compel Docketing\" to the District Court, dated 6/5/2026\nRespectfully submitted,\n.....\nAnna\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 2 of 61\nCourt of Appea\\s ,\nFor The Second C1rcuI1\nTffi m\\\nJE <C JE TI VIE\nUnited States Court of Appeals1_& JUN 1 2 2026 ill}\nfor the Second Circuit\nBY: - - - \"\"\"' - - - -\nIn Re:Anna 3,ct Party in United States v. Kwok, et al. 1 :23-cr-00118-1 (AT),\nPetitioner.\nPETITION FOR A WRIT OF MANDAMUS RELATING TO THE SDNY DISTRICT COURT\nSTATEMENT OF JURISDICTION\nThis Court has authority to issue a writ of mandamus pursuant to the All-Writs Act, 28\nU.S.C. § 1651 (a), because the underlying action is \"within its appellate jurisdiction\".\nSTANDARD FOR MANDAMUS\nTo qualify for mandamus relief, a petitioner must demonstrate:\n1. A \"clear and indisputable\" right to the issuance of the writ;\n2. That the administrative or judicial officer has a non-discretionary, ministerial duty to\nact; and\n3. That the petitioner has no other adequate alternative means to attain the desired\nrelief.\nSee In re Von Bulow, 828 F.2d 94, 98 (2d Cir. 1987); Cheney v. U.S. Dist. Court for Dist. of\nColumbia, 542 U.S. 367, 380-81 (2004).\nSTATEMENT OF RELIEF SOUGHT\nPetitioner is a third party who had filed a \"Motion to Subpoena Luc Despins and Key\nHimalaya Alliance & Farm Personnel; Evidentiary Hearing, & Asserting 853(n) Rights,\nPrivacy and Declaration\" with the District Court, but the District Court suppresses\nPetitioner's legitimate claims and refuses to docket it after Petitioner's multiple requests.\nPetitioner has nowhere to go but r~spectfully ask this Court issues a writ directing the\nDistrict Court to enter Petitioner's Petition onto the docket and address the underlying\nstatutory issues on the merits.\nSTATEMENT OF THE FACTS AND ISSUES\nFacts:\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 3 of 61\n1) Petitioner is a bona fide, innocent investor who has lawfully invested__..\nlife savings in the G-series. These funds are currently seized by, or subject to the\nconstructive custody of, the DOJ, the SEC, Chapter 11 Trustee Luc Despins of Paul\nHastings LLP, or key leaders within the Himalaya Alliance and farms; critically, none\nof these assets were retained by, or remain in the custody of, Defendant Kwok.\nAccordingly, Petitioner is legally entitled to initiate ancillary proceedings over the\nsubject property under 21 U.S.C. § 853(n) to vindicate her cognizable legal interest.\n2) On May 22nd 2026, Petitioner filed a Motion with the District Court by US mail and\n,\nemail. Afterward, despite Petitioner's repeated requests to the District Court for\ndocketing, the Motion was suppressed and excluded from the public record without\nany stated legal justification, as demonstrated by the correspondence attached\nhereto in Exhibit.\nIssues:\n1) The prosecution's designated victims explicitly testified on the record that they\nsuffered no cognizable harm or financial injury attributable to the Defendant -The\nprosecution's victim classification framework (SDNY Doc. 511) reflects a\nsystemic collapse of basic forfeiture principles. The prosecution improperly\nconstructs a closed legal universe where an investor is designated as either a victim\nor a co-conspirator, leaving no procedural mechanism for an 853(n) claimant.\nPetitioner categorically rejects this flawed taxonomy; the Government cannot\nbypass the mandatory ancillary proceeding required by 21 U.S.C. § 853(n) by\nimposing an extra-statutory label on innocent third parties.\nThe Government's victim narrative is fundamentally undermined by the affected\nparties themselves. Pursuant to Doc. 834, the ostensible 'victims', 1254 of them,\nhave formally declared that their financial injuries do not stem from the actions of\nthe Defendant, but are instead the direct result of the Government's disruptive civil\ntakings and illegal possessory seizures.\n2) The prosecution's alleged \"fraud proceeds\" are actually the legitimate funds of the\nG-series investors -The prosecution's unilateral characterization of the G-Series\ninvestments as 'fraud proceeds' (Doc 716-4) represents an impermissible\nexpansion of federal forfeiture authority. Under established Second Circuit\nprecedent, the Government cannot simply declare an entire pool of legitimate third\nparty capital to be the fruit of a criminal enterprise. Petitioner maintains that this\nclassification is legally untenable and structurally invalid under 21 U.S.C. § 853(n).\nPage 2of 5\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 4 of 61\n3) The Government's asset seizure rests entirely upon a legally unproven and\nuncontested 'alter ego' theory that bypassed the mandatory requirements of a\nformal evldentiary adjudication -The Chapter 11 Bankruptcy Trustee, Luc\nDespins, summarily applied an 'alter ego' designation to the entire complex of G\nSeries investment vehicles without ever satisfying the strict evidentiary burdens or\nsecuring the formal adjudication required by law. Compounding this error, the\nprosecution adopted the Trustee Luc's unadjudicated alter ego theory within the\ncontext of this criminal proceeding. This unauthorized coordination effectively\nallowed the Trustee and the Government to rob Petitioner's~\nlegitimate life savings, achieving a permanent deprivation of third-party property\nrights completely unmoored from standard procedural due process. Because this\nasset seizure rests entirely upon an un-litigated alter ego assumption rather than\nconcrete, individualized tracing, the retention of these funds violates fundamental\ntenets of federal forfeiture and bankruptcy law.\n4) The prosecution systematically insulated the Defendant's alleged co-conspirators\nfrom liability, offering immunity in exchange for testimony targeting the Defendant -\nThe anomalous procedural history of this case underscores a manifest injustice that\nundermines the integrity of the judicial process. The prosecutors obtained a\nconviction by immunizing the very individuals who currently possess in excess of\n$100 million of un-seized investor capital (Doc 834), while simultaneously seeking\nto block innocent third-party investors from asserting ancillary claims under 21\nU.S.C. § 853(n). This unusual enforcement posture, shielding possessory, non\nindicted actors while systematically denying a forum to innocent claimants calls\ninto question the structural legitimacy of the prosecution's framework and\nhighlights a systemic failure to safeguard the true victims of the underlying\nenterprise.\n5) An unadjudicated conflict of law wherein the subject asset pool is burdened by\ntwo mutually exclusive designations (Case No. 26-361 )-The District Court has left a\ncritical threshold issue entirely unaddressed, permitting a 'dual-definition' paradox\nto persist over the same asset pool. While the Communist PRC government\ncategorizes the G-Series capital as an illegal political fund targeting state security,\nthe prosecution had summarily branded it as 'fraud proceeds.' Byfailingto hold an\nancillary proceeding to adjudicate this geopolitical and legal conflict, the District\nCourt has abdicated its duty to determine the true legal status of Petitioner's\n~ nl ife savings.\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 5 of 61\n6) Witness duress & evidence tainting -An ancillary proceeding should be conducted\nto address a major structural defect in the prosecution's case: the systemic tainting\nof witness evidence via foreign state interference. The unauthorized transmission of\ninvestor records to the CCP by Phoenix Farm CEO Wei Li hong initiated a wave of\npolitical persecution against domestic investors. Under established due process\nprinciples, a conviction or forfeiture cannot rest upon the testimony of individuals\ninside mainland China who may have been coerced under threat of state violence to\nfalsely characterize their G-Series investments as fraud. Petitioner is entitled to an\nevidentiary hearing to probe this pervasive witness duress and to ascertain the true\nregulatory allegiance of the immunized farm leaderships.\nREASON WHY THE WRIT SHOULD ISSUE\nThe All-Writs Act empowers this Court to issue a writ of mandamus directing the District\nCourt to docket all relevant documents to all parties, including 3,d party Pro Se petitioners\nunder 21 U.S.C. § 853(n). This Court should issue a writ of mandamus because Petitioner\nhas a clear and indisputable right to the writ. No other alternative remedies are available to\nPetitioner. Mandamus is the only avenue by which Petitioners can obtain relief.\nCONCLUSION\nFor the foregoing reasons, Petitioner respectfully requests that this Court issue a Writ of\nMandamus directing the District Court to:\n1. Immediately file and enter Petitioner's Motion onto the official docket;\n2. Authorize and issue subpoenas for the appearance and testimony of relevant, vital\npersonnel; and\n3. Convene a formal ancillary evidentiary hearing as explicitly mandated by 21 U.S.C. §\n853(n) to adjudicate Petitioner's cognizable legal interest in the ~ f\nseized G-Series investment capital.\nPetitioner further requests that this Court review the extraordinary procedural irregularities,\nexercise its supervisory authority to correct a clear abuse of discretion by the District\nCourt, and safeguard the systemic integrity of the federal judicial process by restoring\nPetitioner's fundamental right to procedural due process.\nPRIVACY\nPetitioner respectfully requests to file this petition in redacted public form with personal &\nfinancial data redacted. A redacted set of the documents is provided.\n'\n1\nDate: June 9\", 2026\n\nA-\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 6 of 61\n1 Case 1:23-cr-00118-AT\n2\n3 UNITED STATES DISTRICT COURT\n4 FOR THE SOUTHERN DISTRICT ~O~F__!:!N~E~W_.,.,.,.u.... _____\n5\n6 UNITED STATES OF AMERICA, Motion to Subpoena Luc Despins and\nKey Himalaya Alliance & Farm\n7 Plaintiff, Personnel; Evidentiary Hearing, &\nAsserting 853{n} Rights, Privacy and\n8 Declaration, By~ (Anna).\n9\nv.\n10\n11 HO WAN KWOK (A/K/A MILES GUO, MILES\n12 KWOK, WENGUI GUO AND BROTHER SEVEN),\n13\nYvette Wang,\n14\nDefendants.\n15\n16\nFacts\n17 My name is Anna, a G-series investor, appearing prose to tell the Court my\npersonal experience and facts surrounding my investments relevant to this\n18\ncase.\n19\n1) My background - I am a retired.- a mother, and a Christian who\n20 lives in communist China all my life. I have watched the CCP falsify\nthe Bible, ban its sale, and demand that the Chinese people worship the\n21\nCommunist Party. They tell us that while our parents are dear, the CCP\n22\nmust be 1dearest of all.' Having lived through this spiritual and\n23 intellectual suppression, I am committed to speaking the truth about\nthe regime1s attempt to replace God with the Communist Party.\n24\n2) The taking down the CCP movement - My involvement in the taking down\n25\nthe CCP movement is rooted in my lifelong experience as a victim of\n26 state-sponsored religious and political persecution. Since 2017, I have\nbeen a supporter of Mr. Guo, viewing his movement as a necessary\n27\nvehicle for exposing the CCP's human rights abuses. On June 4, 2020, I\n28\nparticipated in the establishment of the New Federal State of China, an\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 7 of 61\n1 organization dedicated to the peaceful transition of China toward a\ndemocratic, CCP-free future.\n2\nI categorically reject the DOJ prosecutors1 characterization of this\n3\norganization as a 1cult. 1 Such labels are not only inflammatory but are\n4 factually untethered from the reality of the CCP's documented\natrocities, such as forced live organ harvesting on the Chinese\n5\nchildren. I assert my First Amendment rights to freedom of association\n6\nand religious expression, maintaining that my support for Mr. Guo is a\n7 matter of profound personal and spiritual conviction. To dismiss\nthousands of global investors and activists as 'cult members', the\n8\nGovernment is to ignore the legitimate grievances of a population\n9\nseeking liberation from a totalitarian regime.\n10 3) My investment in G-series -The investments I made were part of a\nstructured, global effort to support a free China. Mr. Guo designed and\n11\npromoted an ecosystem of independent entities: GTV(VOG), Himalya\n12\nAlliance, Himalaya Farms, G-Club, G-Fashion, Himalaya Exchange, and\n13 Himalaya Reserve. Each entity was legally established under its own\njurisdiction and managed by its own operational team. My commitment to\n14\nsupport free China this cause was tangible: over a nearly three-year\n15\nperiod from May 2020 to February 2023, I executed 15 separate wire\n16 transfers totaling$ from my hard-earned savings, Using\nlegitimate banking channels and necessary intermediaries, I directed\n17\nthese funds to entities such as VOG, Korean En-Dian Farm, New Zealand\n18\nFarm, G-Club, and Himalaya Exchange. I also donated to the Rule of Law\n19 Foundation. Those capitals were investments in a movement and in\ncorporate structures that I believed in; it was never an 'unlawful\n20\nproceed1 for the Defendant to exploit or comingled personal funds of\n21\nthe Defendant,\n22\nChallenge to the Government's Unlawful Actions Against My G-series Investment\n23\n1) Communist China's transnational Financial Censorship on the G-series\n24\ninvestors - The pain, anxiety, and suffering I have endured because of\n25 my choice to invest in the G-Series is a direct result of the CCP's\ntotalitarian grip on global finance. The Chinese Government\n26\ncriminalized any investment into the G-Series. I knew with absolute\n27\ncertainty that if I disclosed the true purpose of my wire transfers to\n28 the banks, the transactions would be terminated immediately and I would\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 8 of 61\n1 face severe state repercussions, This hostile environment forced me to\nrely on alternative pathways to secure my investments.\n2\n3 In one heartbreaking instance, in 2021, I asked a friend\n4 surnamed ... to use his business account to route approximately ......\nUSO for me through his to ... Because\n5\nof this single act of assistance, the bank froze his entire corporate\n6\naccount for the reasons of \"money laundering\" and \"threatening national\n7 security\". He fought this injustice fiercely, pursuing both a lawsuit\nand an appeal, but he lost both. The Chinese Government fined him and\n8\nthreatened to jail him too. Witnessing the financial ruin of a friend\n9\nwho simply tried to help me escape financial censorship has caused me\n10 immense psychological trauma. My use of intermediaries was never an\nattempt to mislead any financial institutions; it was the only viable\n11\nsurvival mechanism available to an. oppressed citizen trying to move my\n12\ncapital to freedom.\n13\nIn the context of Second Circuit Case No. 26-361, Tony's grievance\n14\nreveals a profound flaw in the DOJ. prosecutors' narrative. The District\n15\nCourt has yet to answer a vital question: How can the identical pool of\n16 money be treated by the PRC authorities as an illegal, 'anti-Chinese\ngovernment' fund that threatens national security, while the U.S.\n17\nGovernment insists it is nothing more than 1fraud proceeds1?\n18\nThis dual classification is a logical impossibility. If the money was\n19 deployed by independent citizens as a financial shield against an\noppressive regime resulting in domestic freeze orders and police\n20\ninterrogations in China, it represents legitimate, hard-earned capital\n21\nrisked for freedom. The Government cannot adopt the asset-pool\n22 dimensions manufactured by the CCP's financial blockade without\nimplicitly validating that regime1s suppression of its own citizens,\n23\n24\nBy failing to address this contradiction, the record remains silent on\n25 a critical distinction. The funds injected into the G-Series by\nindependent investors were sent with clear, anti-totalitarian political\n26\nintent. To treat these politically motivated capital contributions as a\n27\nstandard, unified fraud scheme is to ignore the documented reality that\n28\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 9 of 61\n1 these assets are viewed by a foreign adversary as weaponized dissent,\nnot criminal booty.\n2\n3\n2) The DOJ's reliance on the affidavit of FBI Special Agent AnthonY Alecci\n4 (SONY Doc. 716-4) is legally insufficient to justify the sweeping\n•\nforfeiture of G-Series assets. Agent Alecci cites 18 U.S.C. § 981 and§\n5\n1956 to characterize these funds as 'proceeds1 of wire and bank fraud.\n6\nHowever, this characterization fails as a matter of law.\n7 My capital contributions were made with bona fide intent and originated\nfrom legitimate, post-tax earnings. Under the Second Circuit's 'merger\n8\ndoctrine, 1 the Government cannot classify the mere movement of funds\n9\nbetween accounts as 'money laundering' unless it first proves those\n10 funds were already the proceeds of a completed crime. Here, the\nGovernment has failed to establish a nexus between the alleged fraud\n11\nand my specific assets. Furthermore, the Government's theory of fraud\n12\nis contradicted by the 1victims1 themselves; as noted in Document 834,\n13 the vast majority of investors expressly reject the Government's claim\nthat they were defrauded, asserting instead their status as lawful\n14\nproperty owners under§ 853(n}.\n15\n16 Agent Alecci's investigation (SDNY Doc. 716-4) relies on a logical\nfallacy: that the frequency of transactions automatically equates to\n17\nthe concealment of proceeds under 18 U.S.C, § 1956(a) (1) (B) (ii. In\n18\nreality, my investments were never 'fraud proceeds' to begin with. They\n19 were legitimate investmentS intended for the G-Series ecosystem,\nForfeiture requires the Government to prove a criminal 1taint1 by a\n20\npreponderance of the evidence. Forfeit assets before adjudication\n21\nbefore thousands of investors who overwhelmingly disclaim 'victim1\n22 status {SONY Doc 843), the Government has committed a civil taking\nwithout the required proof of a crime. Moving money between legally\n23\nformed entities is a standard business practice, not a specified\n24\nunlawful activity under 18 U.S.C. §§ 1343 or 1344.\n25\nThe Government's Victim Identification and Classification Crisis\n26\nFrom the standpoint of a G-series investor who rejects victim status, who\n27\nrefuses to proceed under the CVRA, and instead seeks recognition of\n28 independent third-party property interests under 21 U.S.C. § 853(n), the\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 10 of 61\n1 Government's current victim framework is not merely inconsistent; it is\nstructurally unsound and procedurally dangerous.\n2\n1) Selective Gatekeeping of Victim Status\n3\nIn SONY Doc 511, the Government adopted an extraordinarily broad\n4 definition of the purported victim population. It stated that \"one group\nrecognizes the fraud for what it is and believes the defendants\n5\ndeliberately deceived them,\" while \"the other group does not believe they\n6\nwere defrauded (either because they are complicit in the conspiracy, or\n7 they have been misled by it). Many now believe the government wrongfully\nseized their money.\" Under that formulation, the Government's victim\n8\ntheory is broad enough to sweep in not only self-identified victims, but\n9\nalso investors who reject the label of victim and believe the Government\n10 has wrongfully taken their funds. Yet when those same or similarly\nsituated investors appear in court in a procedurally adverse posture, the\n11\nGovernment's framework shifts. After the district court adjourned\n12\nsentencing from April 27, 2026 to June 29, 2026, the Government filed\n13 oppositions to 4 of the Emergency Stay Applications at the Second Circuit:\nRyan Bai (No. 25-2726), Tony (No. 26-361), Chunk Chyi (No. 26-77), and\n14\nCarolyn Sun (No. 26-441). As reflected in Chunk Chyi's response filing in\n15\nSecond Circuit No. 26-77 (0kt. 18), even after he affirmatively invoked\n16 the CVRA and identified concrete financial loss, the Government\nnevertheless sought to characterize him as a mere \"supporter,u rather than\n17\nas a victim entitled to meaningful consideration. Chunk correctly\n18\nidentified the resulting distortion: victim recognition appears to\n19 function less as an equally available statutory protection and more as an\nadvantage effectively reserved to those with representation, procedural\n20\nleverage, or institutional acceptance. This disparity is particularly\n21\nstark, as noted on Pages 3-4 of the filing, where Chunk observed that\n22 certain represented HEX claimants reportedly deny being \"victims,\" but the\nGovernment treats them as \"victims\" in sentencing the Defendant. By\n23\ncontrast, Pro Se petitioners who affirmatively assert loss and invoke the\n24\nCVRA are met with arguments by the Government that their victim status is\n25 insufficient or that their losses should not be counted. The inconsistency\nbecomes even more pronounced in light of the record cited on Page 8.\n26\nThere, Chunk references the defense counsel's submission in SONY Document\n27\n843, reporting that counsel had received 1,254 \"supporter statements.11\n28 Under the Government1s own formulation in Document 511, such individuals\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 11 of 61\n1 would appear to fall within the category of persons who do not believe\nthey were defrauded yet whose funds are nevertheless counted within the\n2\nbroader victim framework. Yet, rather than being treated as victims by the\n3\nGovernment, these individuals were effectively represented through defense\n4 counsel.\n5\nTaken together, the records support a troubling inference: in practice,\n6\nthe Government's recognition of \"victim\" status appears to operate in a\n7 manner that privileges sophisticated representation. Those with counsel,\ninstitutional alignment, or procedural leverage may have their positions\n8\nincorporated into the Government's sentencing narrative, but for the Pro\n9\nSe individuals, the Government labels them whatever the Government sees\n10 fit, sometimes totally against those Pro Se individuals' will. This is not\na neutral application of a statutory framework. It is a structurally\n11\nselective system that conditions access to victim status, and the rights\n12\nflowing from it, on litigation posture rather than legal entitlement.\n13\n2) Selective Gatekeeping of Exit from Victim Status\n14\nThe contradiction becomes even more revealing in the Government's\n15\nopposition to the Emergency Stay Applications filed by the 4 Pro Se\n16 petitioners in the Second Circuit. There, despite the breadth of its own\nDocument 511 definition, the Government effectively treated those 4\n17\npetitioners as supporters of Mr. Guo rather than as persons falling within\n18\nthe broader victim framework it had previously asserted. I myself reject\n19 victim status, refuse to proceed under the CVRA, and identify instead as a\nG-series investor and supporter of Mr. Guo. From that standpoint, the\n20\nGovernment's treatment of those· 4 Pro Se petitioners as \"supporters\" is a\n21\ndeeply troubling. It suggests that the only practical way to escape the\n22 Government's default victim classification and to assert an independent\nposition is to confront the Government directly in court, and to do so\n23\nwith unusual procedural sophistication and persistence.\n24\n25 That is a profound defect in the Government's framework. If only a tiny\nnumber of exceptionally capable litigants, such as Ryan, Chunk, Tony,\n26\nCarolyn and similarly situated petitioners can force the Government to\n27\nstop treating them as passive \"victims\" and instead acknowledge them as\n28 procedurally independent actors, then the Government's classification\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 12 of 61\n1 system is not functioning as a neutral legal framework at all. It is\nfunctioning as a selective gatekeeping device. In practice, it leaves\n2\nordinary G-series investors trapped inside a broad victim label when that\n3\nlabel benefits the Government's loss and sentencing narrative, yet denies\n4 them any realistic path to independent recognition unless they possess\nextraordinary litigation ability. That is not a stable victim framework.\n5\nIt is a procedurally distorted structure that risks depriving ordinary\n6 investors of due process, meaningful access to§ 853(n), and equal\n7 treatment under the law.\n8\nWhat the record reflects is not merely inconsistency of the Government's\n9\nconduct, but the absence of a stable and administrable rule governing\n10 victim classification. A framework that expands to include certain\nindividuals as \"victims\" to support the Government's loss attribution, yet\n11\ncontracts to exclude those same individuals when they attempt to assert\n12\nindependent procedural rights. It proves that the Government operates\n13 without a discernible limiting principle. In practice and in reality, it\nforecloses any predictable or accessible pathway for similarly situated\n14\ninvestors to assert their rights under 21 U.S.C. § 853(n), and thereby\n15\nraises serious concerns not only of fairness, but of the framework's legal\n16 viability.\n17\nConstructive Fraud on the Courts: The Manufacture of an Utterly Fictitious\n18\n\"Alter Ego\" Pool and the Poisoning of the Trial Record\n19 The DOJ prosecutors and Chapter 11 Trustee Luc Despins have engaged in a\npattern of material omissions that amounts to a constructive fraud on the\n20\ncourts. By systematically withholding the fact that a substantial portion of\n21\nthe seized funds comprised untainted, legitimate capital from independent\n22 investors and asserting instead the absolute falsehood that 100% of the\ncorporate assets were \"criminal proceeds11 the Government and Trustee Luc\n23 ,\nengineered a procedurally deficient record to serve a predetermined\n24\nnarrative.\n25 This orchestrated omission produced three devastating legal consequences:\n1) The Artificial Manufacturing of the \"Alter Ego11 Pool\n26\nThe Trustee and the Government bypassed mandatory tracing requirements to\n27\nfabricate a sweeping, all-inclusive \"alter ego\" theory. By failing to\n28 disclose the presence of$ in bona fide capital from me and\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 13 of 61\n1 hundreds of millions from similarly situated investors, the Government and\nTrustee Luc induced the bankruptcy court and the District Court to enter an\n2\noverly broad forfeiture pool. They effectively transformed distinct corporate\n3\nentities with separate fiduciary duties into a monolith, seizing innocent\n4 third-party property under the guise of recovering criminal proceeds.\n2) Structural Deprivation of Procedural Due Process\n5\nBy presenting an artificially clean narrative of total corporate fraud, the\n6\nGovernment and Trustee Luc effectively suppressed the statutory rights of\n7 third parties under 21 U.S.C. § 853(n) before the trial even began. They\npresented the District Court with a curated, unchallenged record, ensuring\n8\nthat any subsequent ancillary proceeding would be treated as an\n9\nadministrative afterthought rather than a mandatory, adversarial adjudication\n10 of superior legal title.\n3) The Contamination and Pollution of the Jury's Fact-Finding Mandate\n11\nThis mischaracterization extended directly into the criminal trial,\n12\nfundamentally infecting the trial record. By introducing high-volume bank\n13 accounts as unified 11fraud accounts\" while deliberately concealing the\nmassive infusions of untainted investor capital, the Government presented a\n14\ndistorted financial landscape. This material distortion polluted the minds of\n15\nthe jury, creating an illusion of total criminality that stripped the\n16 Defendant of a fair trial and starved the jury of the context required to\naccurately evaluate criminal intent.\n17\n18\nA court-appointed Trustee and federal prosecutors owe an absolute duty of\n19 candor to the judiciary. When they actively ignore the distinct, clean origin\nof investor funds to artificially inflate a forfeiture pool, they do not\n20\nmerely commit an error; they perpetrate a constructive fraud that undermines\n21\nthe integrity of the entire judicial system. This Court must intervene to\n22 halt the finalization of this manufactured record.\n23\n24\nMotion to Subpoena and to Conduct Evidentiary Hearing on Luc Despina of Paul\n25 Hastings LLP and Key Himalaya Alliance and Farms Leadership Personnel\nI respectfully move this Court for an Order issuing subpoenas to Luc Despins\n26\n(Chapter 11 Trustee, Paul Hastings LLP), and key leadership personnel of the\n27\nHimalaya Alliance and Farms, including Wei Lihong, Zhang Yongbing, Ha-En,\n28 Cosmos, Guo Shuai, Xia Qidong, William Je and Wang Xuebing. I further request\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 14 of 61\n1 an evidentiary hearing to investigate the potential compromise of investor\ndata and the resulting transnational repression faced by the G-series\n2\ninvestors.\n3\n4 1) Wei Lihong (aka Sarah Wei, MIM~), formerly Arizona Phoenix Farm CEO,\nin charge of the VOG investment.\n5\nBasis for her Subpoena: I assert that Wei Lihong acted as a fiduciary\n6\nfor my investment of$ USD wired to VOG/GTV in . This\n~\n7 investment required the disclosure of my highly sensitive personal\nidentifiable information (PII).\n8\na) Evidence of compromise and transnational repression:\n9\nState interrogation - Following the transfer of funds and PII to Wei\n10 Lihong, I was subjected to three separate interrogations by the\nMinistry of State Security (MSS) of the People's Republic of China\n11\n(PRC) and local police,\n12\nb) Unauthorized disclosure of my data: During these sessions, PRC\n13 officials explicitly stated that my denial of investment was futile\nbecause Wei Lihong had provided a list of \"anti-government\" GTV/VOG\n14\ninvestors and my name was on it.\n15\nc) Ongoing Harassment: As a direct result of this betrayal, I remain\n16 under state surveillance, facing restricted movement and reporting\nto local police during travel.\n17\nA subpoena is required to determine:\n18\n• Whether investors who were betrayed by Wei were systematically coerced\n19\nby the CCP into falsely reporting to the FBI that they were \"defrauded\"\n20 by the Defendant.\n• Whether the written victim statements currently relied upon by the\n21\nDepartment of Justice {Doc. 833) to calculate sentencing and forfeiture\n22\nguidelines were procured under extreme duress by a foreign totalitarian\n23 regime seeking to sabotage the G-Series ecosystem\nA subpoena compelling the testimony of Wei is critical to safeguarding the\n24\nintegrity of these judicial proceedings. Wei's testimony is strictly\n25\nnecessary to uncover a severe breach of investor data that directly impacts\n26 the credibility of the Government's criminal case and the forfeiture pool.\nAnother question is whether Wei is a CCP agent at the beginning but disguised\n27\nas an anti-CCP fighter? How many of the Himalaya Alliance and Farm key\n28\nleaders are CCP agents under cover?\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 15 of 61\n1 A critical issue impacting the integrity of these proceedings is the\npotential role of covert foreign actors operating under the direction of the\n2\nPeople's Republic of China (PRC). An evidentiary hearing is necessary to\n3\ninvestigate whether key figures within the G-Series leadership specifically\n4 Wei and other prominent leaders within the Himalaya Alliance and Farm acted\nas unregistered agents of a foreign power, in violation of 18 U.S.C. § 951\n5\nand the Foreign Agents Registration Act (FARA), 22 U.S,C, § 611 et seq,\n6\n7 It is a matter of record before U.S. federal courts and intelligence agencies\nthat the Chinese Communist Party routinely utilizes 11controlled opposition\"\n8\nand deep-cover operators to infiltrate overseas dissident groups, capture\n9\nproprietary data, and manipulate domestic legal processes. The sudden,\n10 unauthorized data breach of the corporate 11investor list\" to PRC security\norgans raises a profound question of law and fact: Did Sarah Wei operate from\n11\nthe inception of these programs as a disguised asset of the PRC state\n12\napparatus designed to sabotage the movement from within?\n13\nThe potential exposure of multiple undercover CCP operatives within the\n14\nleadership structure of the Himalaya Alliance directly threatens the validity\n15\nof the underlying criminal and forfeiture record. If key organizational\n16 figures were hidden foreign state assets, their cooperation agreements with\nthe Department of Justice, their management of corporate assets, and their\n17\ninteractions with the FBI cannot be deemed reliable.\n18\nTheir operational objective would be perfectly aligned with the geopolitical\n19 goals of the PRC: to engineer a collapse of the G-Series ecosystem, secure\nthe freezing and forfeiture of dissident capital, and manipulate U.S.\n20\njudicial resources to finalize an international financial blockade against\n21\npolitical opponents.\n22\nThe Court cannot permit a forfeiture pool to be finalized when there remains\n23\na substantial, unexamined risk that the corporate leadership who controlled\n24\nthe underlying funds were covertly executing the directives of a hostile\n25 foreign government. Discovery and cross-examination are strictly required to\nunmask the true affiliations of those key actors and protect the integrity of\n26\nthe United States judiciary from foreign state subversion.\n27\n28\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 16 of 61\n1\n2) Luc Despins of Paul Hastings LLP, Chapter 11 Trustee for the Estate of\n2 Ho Wan Kwok (Mr. Guo)\nBasis for Subpoena: As the court-appointed Trustee, Luc Despins has gained\n3\ncontrol over vast amounts of G-series investors' investment including my\n4\nollars wired to G-Club. Trustee Luc has a fiduciary duty to the\n5 Court to accurately report the nature of the estate's assets. However, the\ndesignation of my G-Club fund as the Defendant's personal property is a\n6\nmaterial misrepresentation of the corporate reality:\n7\na) Absence of Factual Nexus: I made bona fide capital contribution of\n8\nto G-Club, a legally incorporated entity with its own distinct\n9 operational parameters.\n10 b) The \"Alter Ego\" Misdirection: Trustee Luc maintained that G-Club was\nmerely an \"alter ego\" of the Defendant to justify his swallowing third\n11\nparty capital into the bankruptcy pool. This sweeping conclusion was\n12\npresented to the bankruptcy court and to the criminal court without an\n13 individualized tracing analysis of my legitimate funds.\n14 c) Constructive Fraud on the Court: By failing to disclose to the Court\nthat a substantial portion of the seized funds consisted of untainted,\n15\nlegitimate capital from independent investors and by claiming instead\n16\nthat 100% of the assets were \"criminal proceeds11, Trustee Luc and the\n17 DOJ prosecutors have engineered a procedurally deficient record, and\nmanufactured Mr. Guo's alter ego asset pool for forfeiture, and\n18\npolluted the mind of juries in the criminal case.\n19\nTrustee Luc has cost the estate millions of dollars in administrative fees,\n20\nyet he has failed to provide a transparent, line-item accounting that\n21 distinguishes between the Defendant's personal assets and my investment.\n22 Proceeding to a final order without allowing me to cross-examine Trustee Luc\nregarding the tracking of my ---investment violates basic tenets of\n23\nprocedural due process.\n24\n3) Zhang Yongbing (~~9'), an immigration attorney of Illinoi, who was\n25\nretained to represent my interest regarding the return of my$\n26 VOG investment. He was designated by the Government as the Defendant's\n\"co-conspirator\" (Document 388). After the Defendant's arrest, Zhang\n27\nappeared on many of the Himalaya Alliance live broadcasts. Allegedly,\n28\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 17 of 61\n1 attorney Zhang represents numerous Chinese political asylum seekers who\nalso invested in the G-series, Allegedly, Zhang played a key role in\n2\nscreening witnesses for Mr. Guo's legal defense and allegedly, Zhang\n3\nprevented some key witnesses who could exonerated Mr. Guo to testify on\n4 Mr. Guo's behalf, claimant like Tony in Second Circuit Case #26-361,\nallegedly,\n5\n6\nReason for subpoena: A material discrepancy exists regarding the return and\n7 custody of my VOG asset. It is a matter of record that numerous similarly\nsituated investors who filed independent claims have already successfully\n8\nrecovered their capital. However, my fund remains unreturned and unaccounted\n9\nfor. A subpoena is necessary to compel a formal accounting from counsel to\n10 determine the current legal status, location, and custody of my\nasset.\n11\nI respectfully direct this Court's attention to an egregious procedural and\n12\nconstitutional defect that invalidates the integrity of the underlying trial\n13 record. As set forth in Document 388, Attorney Zhang Yongbing was explicitly\ndesignated by prosecutors as an unindicted co-conspirator of the Defendant.\n14\nDespite this formal designation, the Department of Justice failed to prevent\n15\nthis exact \"co-conspirator\" from participating in and screening the\n16 Defendant's potential legal defense witnesses.\nThis alarming contradiction introduces two fatal legal errors into the\n17\nrecord:\n18\na) Structural Infiltration of the Defense Camp and Incurable Conflict of\n19 Interest\nUnder the Sixth Amendment, a criminal defendant is entitled to\n20\nconflict-free counsel and a private, uncompromised defense strategy. By\n21\nallowing an individual whom the Government officially considers a\n22 criminal co-conspirator {Attorney Zhang) to act as a gatekeeper for the\nDefendant's trial witnesses, the defense camp was structurally\n23\ninfiltrated.\n24\nZhang possessed an absolute, irreconcilable conflict of interest: as a\n25 named co-conspirator seeking to avoid his own indictment, his primary\nincentive was to protect himself and cooperate with the prosecution's\n26\nnarrative-not to assist in developing a robust defense or locating\n27\nuntainted investor capital.\n28 b) Prosecutorial Exploitation of Witness Screening\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 18 of 61\n1 The Government cannot have it both ways. Prosecutors cannot brand an\nattorney as a criminal co-conspirator in official court filings to\n2\ndestroy their credibility, while simultaneously allowing that attorney\n3\nto control, vet, and filter the witnesses available to the defense.\n4 This arrangement effectively gave the prosecution a proxy inside the\ndefense infrastructure, allowing an insulated co-conspirator to\n5\nsuppress or discourage critical testimony from independent investors\n6\nwho could have proven that the G-Series funds were legitimate and\n7 untainted.\n8\nThe deployment of an unindicted co-conspirator to oversee or influence\n9\nthe screening of defense witnesses represents a profound subversion of\n10 the adversarial process. It suggests an orchestrated effort to control\nthe narrative, sanitize the trial record, and deny the Defendant a fair\n11\ntrial. A full evidentiary inquiry into the scope of Attorney Zhang1s\n12\ninterference with the defense witness pool is necessary.\n13\n14\n41 Ha-En <~*JI<:!/') and Cosmos(~~~), both were former Korean En-Dian Farm\n15\nCEOs; William Je of ACA Capital; Xia Qidong (aka Longisland brother,\n16\nChangdao, ][;ltJR), former Himalaya Alliance Chairman, Mountain Spice Farm\n17\nCEO; Guo Shuai ($ililji • 1,l:;l,1VJ,'llf, Chaogen Xiaoge), Himalaya Alliance leader\n18\nI\n19 On 2020, I wired $ dollars to the Korean En-Dian Farm Loan\nProgram. Ha-En said that CEO Cosmos who was sent by the Himalaya Alliance\n20\ntook the money. But on ~2022, Guo Suai (Chaogen Xiaoge), an Alliance\n21\nleader made a public announcement alleging that team Cosmos had committed\n22 fraud and he was suing team Cosmos.\n23\nReason for subpoena:\n24\na) In Government Document 273, the DOJ prosecutors asserted that ACA Capital\n25 received $130 million in Farm Loan capital. ACA Capital is a distinct\ncorporate entity with no legal, financial, or familial ties to the Defendant,\n26\nthe Defendant's family, or his family trust.\n27\n28\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 19 of 61\n1 b) In Document 804, the Defendant stated that a number of independent\nHimalaya Alliance CEOs and others hold custody and possession of\n2\napproximately $100 million in capital including the Farm Loan fund.\n3\n4 A subpoena is required to compel these individuals to testify under oath and\nproduce financial records clarifying the true custody and ownership of the\n5\nFarm Loan assets. I seek to expose a fundamental flaw in the prosecution's\n6\nlogic:\n7\n• The Tracing Failure: If $130 million of the Farm Loan capital is held\n8\nby ACA Capital and or separate executives {Himalaya Alliance CEOs) and\n9 or others, the Government cannot meet its statutory burden to prove\nthat these funds represent the Defendant's criminal proceed.\n10\n11 • The Manufactured \"RICO Enterprise\": By blindly pinning the independent\nfinancial actions of ACA Capital and the Alliance CEOs onto the\n12\nDefendant, the DOJ prosecutors have manufactured a fictitious RICO\n13\nasset pool. They have converted independent, third-party corporate\n14 capital including my own contributions into a centralized \"criminal\nenterprise\" without performing the mandatory line-item tracing required\n15\nby Second Circuit case United States v. Banco Cafetero Panama, 797 F.2d\n16\n1154 (2d Cir. 1986).\n17\nThe Court cannot allow the Government to seize an entire corporate ecosystem\n18 under a RICO forfeiture order when the record proves the Defendant lacked\nownership and control over $100 million dollars of the funds in question.\n19\nSubpoenas must be issued to ACA Capital and the Himalaya Alliance leadership\n20\nto compel a transparent accounting and halt this unconstitutional inflation\n21 of the forfeiture pool.\n22\n23 5) Wang Xuebing (or Wang Xuebin, 3'.<g/Jjq, CEO of the New Zealand Farm and\nHimalaya Alliance Chairman\n24\nThe testimony of Wang Xuebing is vital to resolving a core dispute of fact in\n25\nthis forfeiture proceeding: whether the G-Series Farm Loan funds were the\n26 \"alter ego\" of the Defendant or whether they were entirely controlled,\nmanipulated, and withheld by independent regional operators.\n27\n28\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 20 of 61\n1 My specific transactional history provides prima facie evidence of\nindependent third-party management and potential self-dealing:\n2\na) The Capital Contributions: Between 2020, and\n3\n2022, I executed a series of wire transfers totaling\n4\ndirectly to the New Zealand Farm Loan program.\n5\nb) Procedural Irregularities: At the direction of Mr. Wang's direct\n6\nsubordinate {Wen Xiao), I was instructed to execute a blank Farm Loan\n7 contract, specifically was told to omit the date and the dollar amount,\nleaving only my signature (attached hereto as Exhibit). This highly\n8\nirregular procedure ensured the contract was never properly executed or\n9\ncounter-signed by Wang Xuebing, leaving my fund entirely exposed.\n10\nc) Post-Arrest Unilateral Modification: The Defendant was arrested on\n11 March 15, 2023. Months later, ontll■■■■, 2023, while the Defendant\nwas in federal custody and completely unable to attend any corporate\n12\nentities events, Wang Xuebing executed a unilateral contract extension\n13\n(attached hereto as Exhibit), arbitrarily extending the Farm Loan\n14 maturity term by an additional two years without my consent or\nknowledge.\n15\n16 The Government's forfeiture case relies on the theory that the Defendant\nmaintained unfettered dominion and control over all incoming investors'\n17\nfunds. Mr. Wang's actions completely refute this:\n18\n• Independent Dominion: The fact that Wang Xuebing could unilaterally\n19\nalter financial contracts and retain of my capital after\n20 the Defendant1s arrest conclusively proves that the Defendant did not\npossess or control these funds.\n21\n22 • Investigating Potential Conversion: I have a right under Fed. R. Crim.\nP. 32.2(c) to discover the current location and custody of my asset.\n23\nMr. Wang1s deceptive practices strongly indicate an intent by local\n24\nleadership to convert the Farm Loan program capital to their own\n25 personal use, entirely independent of any alleged conspiracy by the\nDefendant.\n26\nThe Government cannot legally forfeit my as property of the\n27\nDefendant when an independent operator in New Zealand is actively altering\n28\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 21 of 61\n1 contracts and withholding the funds. A subpoena is strictly necessary to\ncompel Wang Xuebing to account for the precise location of my capital and to\n2\nexpose the fatal defects in the Government's \"alter ego\" forfeiture\n3\nnarrative.\n4\n5 In conclusion, the current evidentiary record in this case is fundamentally\nflawed because it relies on the unvetted narratives of individuals who have a\n6\nprofound financial and legal interest in concealing the truth. As established\n7\nin Document 388, individuals such as William Je, Xia Qidong, Wei Lihong\n8 (Sarah Wei), and Attorney Zhang Yongbing are designated co-conspirators of\nthe Defendant.\n9\n10 Upon information and belief, Xia, Wei, and Zhang have entered into non\nprosecution, cooperation, or immunity agreements with the DOJ. In exchange\n11\nfor accusing the Defendant of wrongdoing and su~porting the Government1s\n12\nnarrative, these individuals have been insulated from indictment.\n13\nThe structural defect in the Government's forfeiture and criminal narrative\n14 rests on three critical realities:\n15 a) The Insulated Parties are the True Custodians of the Assets\n16\nWhile the Government ha~ systematically pinned 100% of the financial\n17 liability on the Defendant under an overbroad \"alter ego\" theory, the\ndocumentary evidence demonstrates that it is these unindicted co-conspirators\n18\nwho exercised autonomous control over, and actively withheld my capital,\n19\nincluding the$- VOG investment handled by Sarah .Wei and later by Zhang\n20 Yongbing.\n21 b) Weaponized Coercion and Witness Bias\n22\nBy granting immunity to the very operational leaders who managed the day-to\n23 day transactions of the G-Series entities, the Government has incentivized\nthese actors to mischaracterize legitimate third-party capital contributions\n24\nas \"fraud proceeds, 11 This arrangement allowed these co-conspirators to\n25\ndeflect criminal culpability while simultaneously shielding themselves from\n26 accounting for the missing investor funds.\n27 c) The Absolute Necessity for a Rule 32.2(c) Ancillary Hearing\n28\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 22 of 61\n1 My right to due process cannot be bypassed by an administrative agreement\nbetween prosecutors and self-interested co-conspirators. To determine the\n2\ntrue \"taint11 and ultimate disposition of the seized property, these\n3\nindividuals must be formally summoned to court. I have a statutory right to\n4 subject these witnesses to rigorous cross-examination at a mandatory\nevidentiary hearing to uncover the location of her missing property and\n5\nexpose the manufactured nature of the forfeiture pool.\n6\n7\nFor the foregoing reasons, I respectfully request this Court to vacate the\n8\npremature forfeiture determinations and remand this matter with instructions\n9\nto issue the requested subpoenas and immediately convene a full ancillary\n10 proceeding.\n11\n12 Preyor For Relief\n13\nWHEREFORE, I respectfully request that this Court enter an Order granting the\n14 following relief:\n1. Recognition of Statutory Title: Formally recognize my standing and\n15\nproperty rights as a superior·, bona fide owner under 21 U.S. C. § 853 (n)\n16\nregarding all documented capital contributions made to the G-Series\n17 entities;\n2. Issuance of Subpoenas: Issue subpoenas ad testificandum and duces tecum\n18\npursuant to Federal Rule of Civil Procedure 45, compelling the\n19\nappearance and production of records from the following material\n20 witnesses:\no Luc Despins, Chapter 11 Trustee (Paul Hastings LLP)\n21\no Wei Lihong (Sarah Wei), former CEO of Arizona Phoenix Farm\n22\no Attorney Zhang Yongbing, legal representative for investor claims\n23 o Wang Xuebing, CEO of the New Zealand\no Guo Shuai, Ha-En, and Cosmos leadership personnel\n24\no William Je, ACA Capital;\n25\n3. Conduct Evidentiary Hearing: Convene a full ancillary evidentiary\n26 hearing pursuant to Federal Rule of Criminal Procedure 32.2(c} to\naccurately determine the true, traceable dimensions of the forfeiture\n27\nasset pool; and\n28\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 23 of 61\n1 4. Additional Equitable Relief: Grant such other and further relief as\nthis Court deems just, proper, and necessary to protect Petitioner's\n2\nprocedural due process rights and prevent a constructive fraud upon the\n3\nCourt.\n4\nPrivacy/ Sealing Request Under Fed. R. Crim. P. 49.1\n5\nI respectfully request to file this motion in redacted public form (redacting\n6\nname, address, email, phone, financial data and sealing my ID information\n7 such as name, address, DOB, ID# etc.).\n8\nDeclaration\n9\nI declare under penalty of perjury that the foregoing is true and correct to\n10 the best of my knowledge and belief.\n11\nRespectfully submitted,\n12\nDated, May 21, 2026\n13\nAnn~\n14\n15\nCertificate of Service\n16 I certify on May 21, 2026, submitted this filing to:\nThe Court's Pro Se Intake for docketing\n17\nvia email ProSe@nysd, uscourts. gov\n18\nand\n19 via US Mail:\nClerk of Court\n20\nUnited States District Court\n21\nSouthern District of New York\n22 500 Pearl Street\nNew York, NY 10007\n23\n24\nUS Attorney's Office SONY:\n25 • ryan.finkel@usdoj.gov (Ryan Finkel, Assistant US Attorney)\n26 • justin.horton@usdoj.gov\n• micah.fergenson@usdoj.gov\n27\n28\nDefense counsel:\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 24 of 61\n1 • msarafa@sarafalaw.com\n2 • jdratel@dratellewis.com\n• jkaley@doarlaw.com\n3\n4\nAttachments/Exhibits: Personal ID, Investment Proofs and Evidences\n5\nRespectfully submitted,\n6\n7\nSignature~\n8 Print: Name Anna\nAddress:\n9\nTelephone:r:i,\n.10\nEmail: _._\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 25 of 61\nLIST OF THE ATTACHMENTS/EXHIBITS\n1) MYID\n2) SUMMARY OF MY INVESTMENT\n3) PROOF OF MY INVESTMENT -19 PAGES\n4) -FROZEN FRIEND BANK\n5) AGREEMENT WITH ATTORNEY ZHANG YONG BING TO GEl ftj 1/OG REFUND\n6) KOREA EN-DIAN FARM MATTERS\n7) NEW ZEALAND FARM LOAN MATTERS\n\nCCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 2266 ooff 6611\n. . ... .. .. .\n..\ntT hh ee M Pi en oi ps lt er 'y\ns\nof\nRe\nF po ur be li oig ncn d, se o l f mf ia li C it h ts i an ra\ny\nforeign cornit\nc # XE MI FI\n-PEOPLE'S\nREPUBLIC OF CHINA\nCHŇ\nEPASSPORT ..\nPE / CHINESE\n公安部出入境管理局\nMP'S Bit & Entry Administration\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 27 of 61\n-\n,~\nOATE !!_OM MY ~q)l)ff! TO ACCOUNT tl'WAOUGH JJW PAATY/MIOOl.E MA/I!) AMOUN< ~USO\n=\n~ AGFtlOJLTUAAl SAN( CF 0-!INA; S(L,f, ACCf, \\l.t1:<LS~AI! - =\n......jj ijiji>'l AGRlCULTUAAL !lAN)( OF 0,1NA, SE:U:, A; W'El~FARGO, -\nTOTAi. VOG/R£P'IU.S£NT£0 eY ATTORNEY ZHANG YONGBING -\n- STANOAAOO·iA$T(R$.<l.Nl(.s(lf,ACCT NONGl'!YUPSANJ(, - USO ,.oot,,(. . :-,,,. . , ....... ~\nTOlAl TO KOREAN £N DIAN FAAM I.O.v! HA-EN/COSMOS - s\n-\n' s ......, O 0,i 1lN NA A C COO NN Ss 'In R! WU Ccr l\"t IO ON N e 8A ,AN N.! lC (;. -S sf n.l. FF ;, A ACC CT Cii T9 .I -I - • \" ,u\" A\" N' RRA A.T nT: ~@I Ll. 77 ,- .,;v,~ :i........• ..::,. . .. .. ... .. . . <. .: ¢;; .1., .. '1,i\n' lii 1~ COJ\\ISTRUC!10N f.,>,NK. s.flF; Al::CT ... '\"\"\" RA.TT: f! 1·7 --~.,~.,..,~,...,~,.,.\n' :NA, CONSTRucr10N BANI(; SELF', ACCT~ YUAN RATE@l:7\na 11'<A.CONS'TiUJCTION BANIC;SE:lf;~. .. - ,UAN AAT'£ql:1 -~•--<OJ.N~~\n• AGRICUtTlJAAI. 6ANKOJ OllNA;SEtl';ACCT-- ,UL, RATI:@ 1.:?. _l;l.........:,,...,wu:.,..•-.;,\n,UAN s -\n-\n\" _411_111 _1_11 !' 'O'IINA C.ONSTRUCTlON BAN.K,.S£U', ,UAN\nll 0-11\"-A CONSTRV<TlON BA.Nltstlf;.ACCT ,UAN\n,N CONVEl'ITTO T.- ,UAN «:,. ... -.==..,,i.=,\n-\n\" ,,,,,,_. O'llNA CONSTRUC'. {J. Q l,18,AN' ,,.,,,o \"\"'\" f,O,uO~.:,~)U\n..,\n\" ....... .llGRlC..lTlJAALSANKOl'CHlN~_Sl:LF.~ ,UAN\n\" -._...._-. ~_JNACO_IIISTR VCTION BANl(;.Sf '\"\"'\n,UL, ~acma,o:==\nTOTAi. TO GOJJB '\"\"' $\n\" U'lB/2023 AGJ.llCVLTU~L 13AN(OF O!INA \"\"' -V5QT',. .- -:. ...\nTOT~ TO H-001.1.AA,.hJSf:DTO BIJ'nt<QU,j_-':_l.10_~~ .!_UCM\nGRANO TOTAL FOR All INVESTMENT\n\nCCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 2288 ooff 6611\n汇款详情\n账 户\n款\n你子账户 美元肌汇\n0.00美元(手续费)\n0.00美元(电报费)\n国际支出金额 小美元\n汇款状态 受理成功\n收款方名称\n收款账户\nSWIFT/BIC\n收款银行名称 WELLS FARGO BANK, N.A\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 29 of 61\nNAMIC\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 29 of 61\nULTURAL BANK OF CHINA\n交易类型:汇出非款\n受理终端:\n发光案号\n客户姓名气\n交易结果:交易成功\n出证金额\n成交汇率\n收款方姓名:THING RET\n汇款金额:\n汇头巾神:美元\n费用承担方式:共同承担\n于续费:\n邮电费\n附言:\n受理日期/时间\n行 股份 有\n限\n公\n\nCCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 3300 ooff 6611\n不易所需的短信验证码为\n转入账户居民 收款,\n产的金额 USD。切勿\n将验证码告知他人!请警惕电信\n作骗,切勿向陌生人转账汇款。\n● EMUI已防止第三方应用服避读取和使用\n上证码:超级游离世人,\n自制验证码\n尊敬的客户,您\n本次海外电汇申请(序列号\n已提交\n处理。\n2分钟\n尊敬的客户,您\n本次海外电汇交易(序列号\n“已成\n功。\n2分钟前\n的\n您尾号\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 31 of 61\n-\nBH 1E K9aA\nA\nMN r c- &\nc\nT\nom rC oeu\nu\nnrs\nsn\nt c oo tu cm ts Ne it or uo\nn\nm mN Pe ba er e\nr\nMm r ia : oe i cl hing Address: 「 I人 ndi活 vid期 ual账 Ac户 cou交\nnt\nT易 ran明 sac细 tion D\n交易白期\nPosting Date Transaction Date 收 支 出 I入ncome/\nExpense\nAmount\nBalance\nTransaction\nName\n2020\n2020\n利点\n支\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 31 of 61\n出\n转账\nEND\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 32 of 61\nYMA (TWEN)\n将702, 721, 373韩币, 칠억이백칠십이만일천상백칠십상원\n韩币交予联盟委托收款人:\n1. 營團(溫暖姐姐)\n2. 成先钠(西朝鮮)\n3. 王環皓(至時时刻)\n地点: 서울시 도림동216-2.\n查验并交付完成\n2021.04.05\n委托人签字 付款人签字 收款人签字 사\n1.성선 명\n1.\n2 张丽\n2\n3.主張皓\n•\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 32 of 61\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 33 of 61\n交易账户 建设银行\n交易时间\n交易地点/附言 跨行转出\n对方账户\n记账日\n账户余额\ntt:\n,'\"<'\nJ=Y\n~;<)\nJ<)\n~~<)\nJl(\n*\nm}8\nm}8\nm}8\ntJ\n1=>\n}l\n%\nII=>\n9}\nlII\n*\n%\n~\n~\n*\n,-\n}I\nr-o~\n}l\n}A'l!\nI.!!!.\n1l=l\n~. ~ ~HD\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 33 of 61\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 34 of 61\n跨行转出\n交易账户\n交易时间\n跨行转出\n交易地点/附言\n对方账户\n记账日\n一 -\n,~,\nr¢)\n~<)\n~~<)\n.it:\nJ7(\n~\n~\n~\ntr::;\n]:~\n=\nK,o\ns\n9}\n4\n~\n]JI\n~\n~\n}t\nj!!!,\nrG~\n}I\n~ ~ tllD\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 34 of 61\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 35 of 61\n跨行转出\n¥ 00\n交易账户\n交易时间\n交易地点/附言 跨行转出\n对方账户\n记账日\n账户余额\n1::=:>\n~<)\nt¢>\nt~<)\n+J\n.'( .', .': L'\nuIJ,~,r,<\n- '1\n'\n·,.r.,\nD1)s\nD1)s\ntr::~\nt:?:>\n1l\n~\n-·~}:.'V \"''\"·\n.$\nM\nJ:S;\nJD\n>'*\n~\n,!':!\n,-\n}1'\nrD~\n}1'\n});iJ\nJEJ\nIJ;::::>\n'\n~ rllD\n•\n0 0\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 35 of 61\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 36 of 61\n跨行转出\n交易账户\n交易时间\n交易地点/附言 跨行转出\n对方账户\n记账日\nI\n-1¢}\nJ<)\n~)<)\n.it::\nIJ\"\"\\ Jl[\ntJ2\n~\n~\n~\n=\n3;\nm\n~\n+:::L\n~\n,r:,r\nrL\nrD?\n}1\n~\n~ !:s: ~ ~IID\n- IJ\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 36 of 61\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 37 of 61\n交易类型 向他行账户转站\n交易渠道 手机银行\n转账金额\n大写金额\n凭证号\n收款方\n户名\n账号\n收款银行\n付款方\n-\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 37 of 61\n- -\n-\n户名 电子回单\n专用章\n账号\n\n\\/\n,\nh\n.\n~\n~ ~J\n'\n~ ->\n~ }I\n..\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 38 of 61\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 39 of 61\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 39 of 61\n务凭证\nMÍMỘTVỊ\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 40 of 61\n跨行转出\n¥\n交易账户 建设银行\n交易时间\n交易地点/附言\n对方账户\n记账日\n...\n'/(''\n.\n,.\n:,\n.\n.. ,.-,,,.,•,\n, ...\n.,;,'\n·'\n..\n. ,I\n,I;<}\n-I)<)\n~)<)\nit:\n'\n~\n~\n~\n~\n=\n,·\n..\n~\n4\n~\n~_,fP\nJJI\n}\n,-\n}I\nJ!!J\nrD~\n}I\n\"\n~ ~1m\nI ,\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 40 of 61\n\n'\n'\n~ •\nI\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 41 of 61\n\nCCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnnttrryy:: 11..11,, PPaaggee 4422 ooff 6611\n交易时间\n交易类型 问他行账户转账\n交易渠道\n手机银行\n转账金额\n大写金额\n凭证号\n收款万\n户名\n账号\n收款银行\n付款方\n\nCCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 4433 ooff 6611\n通知收款人\n付款人\n收款人\n收款账户\n收款银行\n交易时间\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 44 of 61\n跨行转出\n交易账户\n交易时间\n交易地点/附言\n对方账户\n记账日\nr¢>\nr¢)\n~~<)\n~\nu''r\"\nt\nt]\nr\"\nti:::\na\na\n~\n~\n~\n~\n'\nl:p\ns\nm\n>t\n.\n~\n,\n-4\n~\n~\n(\n'\nJBJ\nrD~\nrL\n}~~ j,:\n'\n,'\n)''•\n~ tllll\nJ\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 44 of 61\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 45 of 61\n1 一 2 す 1 一 一 -\n付款人\n付款账户\n收款人\n收款账户\n收款银行\n转账金额\n-\n- 一\n川\n红\n色\n_..._\n..\n•,,_I\n4\n. .~\n· .\n.•~\n·~\n.\n:li/1\n..\n~i\n~i\n'\n~·\n·~\n·~\n~·\n->\n->\n~\n.~\n.~,\n......\n~\n'\n}1\n}1\nII-'\n~\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 45 of 61\n\nCCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 4466 ooff 6611\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 47 of 61\nTHE\nJ上 UA海 NGU商 AI業 CO儲 MME蓄 RC銀 IA行\nL\n&國 SA際 VIN金 GS融 DA業 RK,務 LT分 D Q行 UU DRANCIL\nCURRENT ACCOUNT WITHIDRAW SLIP AND APPLICATION FOR OUTWARD ELSINITAN\nDate\nft It - 1/\\Ve dechart that I/we am are not a local individual, corporate body of govemment In\nnt ofitince and\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 47 of 61\nE\nS E\nchar\nhorized to debit miyfour AIC No.2710800 EX\nB\na\nn\nk\n'\ns\nC\no\np\ny\n會國士全小限度,段便會日自上門休产主で\n一\n\nCCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 4488 ooff 6611\n今天美元 率是\nF+匯款手線\n今天人民币\n十共需要:\n款项最慢后天会到,您到时确\n认一下。\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 49 of 61\nall\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 49 of 61\n中国移动 つ\n目前二审,主要是针对刑期和\n罚款金额两个部分,金额问题\n不大,最主要刑期减轻是关键\n\nCCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnnttrryy:: 11..11,, PPaaggee 5500 ooff 6611\n-\nPrivileged and Confidential\nService Agreement\nClient), agree to sign the legal service agreement with Law Offices of Yongbing\nZhang (ZYB & Associates LLC, or \"The Firm\") for asset distribution from the\nFair Fund administrator. The Firm will provide the roll\n2.\nfiling claim form with supporting documents on my behalf with GTV Media Group Fair Fund\nb. bying to secure the distribution of my proportional investment fund for GTV media group from\nOTV Fair Fund (\"the Fair Fued\") created by the United States Securities and Exchanges Commis-\nsion (SEC) under the File Number of 3-20537;\nc. depositing the secured distribution from the Fair Fund to the Firm's client trust account (toast so-\ncount). if the Firm's efforts result in successfid and favorable distribution for me:\nd. maintaining the secured distribution in the client trust account of the Firm until my authorization\nto withdraw it out of the trust account\n3. Excluded Start\nThe Firm is not hired to:\n1) litigate against any parties regarding your right in GTV Stock or Digital Assets; 2) increase the value of\nyour recovered investment through making investment in the market or making loens to other parties, which are\nbeyond our expertise; and 3) other unrelated maters to the Engagement\n4. Legal Fees kad payment\nI agree to the attorney fee at 1% of the requested distribution refund sought by me, which is\n$ at this time, but is subject to change in the course of representation.\n3. Generator Law and Dispute Resolution\nThis agreement is governed by the law of State of Illinois of the United States By entering this agreement,\nI give the United States federal or state courts in Cook County of Illinois the exclusive jurisdiction to resolve the\ndisputes out of the agreement.\nAGREED by:\nDare\nAGREED by:\nYoogbing Zhang on behalf of ZYB & Associates LLC\nYoughing Zhang\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 51 of 61\nII!; Iii\nNBllttJJ~fill(ftftfffJ.»lftl,f>llf)Vdt.\n'fl011~,A\\U,\nfUU:\nU)ft (~A+M•I\n~d(fN,1,UJ\nttm m, 17lft-!II. 11.tftlllfVtlQoJBtfMtil'tlldlfl\nm,it;tt,'.■-ft\\UU1 •\n1 UY IIRllll\nl. Otl<IM>\nJ.. :nil IJ MtttO ..\n1U1 .>-11-4 .!:.llll16·t\nft1f:,t:_HU\n~~\n{/{.it)·\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 52 of 61\nApril 10, 2022\n•\n~ffi/J\\lf\n2022/4/10, 09:23\ntj~ a{J~{u.ldt~::kJ~~9:f :\n1~.Pfrfi 1=5 llRnOO?i:lt!l~±m~u~)i'H±:5!tl=H&'.\ncosmos@ltk ()/!;~Am. EHt: cosmos, ).ffi\\Blffi\nffi, if!H-#8065, ~+#6311, Jllii;~lm~) i'l=filiu\nuis:, it=f!m ffi ~~ f\" a{] i!lt&: §'I im~~ trfi ~\n.~,, #.§..t{~M'iJ£~1=5~ff~~~~Vifi, 1fVifi~*ll\n!.@1$8~1iEf.@fo.lcosmos1'l=filiu!fil{!k~it9.Wi'sl,g!i,-J-~\n1'1= 9.\\iu a{] U ~\n:m~~filiua~~~1n~~lfcl15m~. ~1n~111J:En\n00>~1$1?1l~A~•~~~i'l=filiul?1l{!kYitZt($, 93~**\n~!llia~~f\"\nhttp\nn\n~a ?m!I! )li-tv~ifiliJiijl~ 00 ~tib a{] fiJ. ~ Af H jj/1\nltD%~\n\nCCaassee:: 2 266--11662266,, 0 066//1122//22002266,, DDkkttEEnnttrryy:: 11..11,, PPaaggee 5533 ooff 6 611\ndul.Final_Version pot\n金額先空筆記事或许振惠客一下大\n汇軍计算 台灣選派先空瓣\n金額扫日期影先空著不填 !.\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 54 of 61\nPURSUANT TO AGREEMENT OF AUGUST 1,\n2020\nTO: LENDER\n•\nLENDER'S Email:\nFJOM.BOU.OWD.\nY~tol.-1td\nIHAl-'-IPl~ttlltbm.A.'lldlla6..Hw~l140\n,_.....,\n,-.111--. ... ocwt-............. Nlf\"dll,lOZO,ll ..... l(f)-\nl ......... )\"<;Ml .... ~ .. ndol'IJlbtfat.l~--~.ttw\"\"-....-u_.,._\n~,-,,.~ .......... - ..l lfr\no.i.-.,..,...,,.?Oll\n•\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 55 of 61\nM(J_\nc~\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 56 of 61\nFrom: Pr e Filing <pro .1:e m1ng@1W$d,uscourts.gov>\nDate: o Friday, May 22nd, 2026 at 12:04 PM\nSubject: ATION, PLEASE REVIE\nTo\nIMPORTANT INFORMATION, PLEASE REVIEW\nYour email has been recei\\led by the Pro Se Intake Unit of the United States District Court for the Southern District of New York, {This Is not the\nUnited States Ba_nkruptcy Court,)\nDocuments from prose litigants that meet the required standards for electronic filing will be filed and wlll appear on the ECF docket withln two\nbusiness days of receipt (see required standards below). If you send your document by email and It Is accepted for filing, you should not deliver\na hard copy version to the court.\nRequirements for Flllng a New Action by Emafl:\nDocuments must be attached to the emall In PDF fonnat, no larger than~ megabytes;\nThe complalnt must be signed by the filing party;\n•\nFee requirements and Instructions:\n•\nPlease note that your comp la Int wlll not be revlewed until the court receives payment of the flllng fees,\nPayment must be made within 30 days of lhe date your case Is assigned a docket number. If rnaUlng payment, please send a\ncertified check, bank theck, or money order to: Cuhlers Room 260, 500 Pearl Street, New York, NY 10007.\nYour payment must include the docket number, which you can leam by cal11ng (212) 805·0175.\nIf you have not consented to e-servlce, your docket number will also be malled to you, at the address provided on the complaint, in\na form order tMt will Include payment Instructions. If you do not make payment within 30 days of the date a docket number ts assigned to your\ncase, the action will be dismissed without preJt1dlc.e.\nIf you cannot pay the filing fees and want to reqllest that the court waive the filifl8 fees, you must email an MP.lication to proceed in\nformo oquptris.\nFilfng Documents In an Existing case by Emal!:\nDocuments must be attached to the email In PDF format, no larger than 10 megabytes;\nThe email and attached document must contain the docket number, filer's name, address, and telephone number;\nDocuments must be signed by the filing party;\nAny additional comments, questions, or other messages In the emall w\\11 be disregarded;\nAny additional correspol'ldence Included In the email will be disregarded.\nFor any submission, If your document does not appear on the ECF docket within two business days, It has not met the required standards for\nelectfontc filing. If so, you must submit your document to the court In paper form by (a) sending your document by mall, or overnight delivery\nservice, to the appropriate courthouse listed below; or (bl delivering your document In-person to the appropriate courthouse Usted below\nbetween the hours of 9:30 AM to 1:30 PM; or (c) depositing your docutnent after hours In the court's night depository box at the 500 Pearl\nStreet, NV, NY courthouse.\nUnited States Courthouse\nP,o Se Intake Unit\nS00 Pearl Street\nNew York, NY 10007\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 57 of 61\nC\nAnna ( ) DOCKETING STATUS case #1-23-cr-118(AT)\nI would like to know the docketing status on my May 22, 2026 filing -if there is a requirement that has not been met\nfor the filing to be docketed, please advise.\nThank you.\nRegards.\nAnn....-..\nG-series Investor\nChina\n------- Forwarded Message------\nFrom: •\nDate: On Friday, May 22nd, 2026 at 12:09 PM\nSubject: Fw: IMPORTANT INFORMATION, PLEASE REVIEW\n\"\n------- Forwarded Message -------\nFrom: Pro Se Filing <pro se filing@nysd.uscourts.gQl!>\nDate: On Friday, May 22nd, 2026 at 12:04 PM\nSubject: IMPORTANT INFORMATION, PLEASE REVIEW\nTo:\nIMPORTANT INFORMATION, PLEASE REVIEW\nYour email has been received by the Pro Se Intake Unit of the United States District Court for the\nSouthern District of New York. (This is not the United States Bankruptcy Court.)\nDocuments from pro se litigants that meet the required standards for electronic filing will be filed\nand will appear on the ECF docket within two business days of receipt (see required standards\nbelow). If you send your document by email and it is accepted for filing, you should not deliver a\nhard copy version to the court.\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 58 of 61\nIMPORTANT INFORMATION, PLEASE REVIEW\nFrom Pro Se Filing <pro_seJiling@nysd.us urts,gov>\nTo\nDate M\nIMPORTANT INFORMATION, PLEASE REVIEW\nYour email has been received by the Pro Se Intake Unit of the United States District Court for the\nSouthern District of New York. (This is not the United States Bankruptcy Court.)\nDocuments from pro se litigants that meet the required standards for electronic filing will be filed and\nwill appear on the ECF docket within two business days of receipt (see required standards below). If\nyou send your document by email and it is accepted for filing, you should not deliver a hard copy\nversion to the court.\nRequirements for Filing a New Action by Email:\n• Documents must be attached to the email in PDF format, no larger than 12 megabytes;\n• The complaint must be signed by the filing party;\n• Fee requirements and instructions:\n• Please note that your complaint will not be reviewed until the court receives\npayment of the filing..fu§.\n• Payment must be made within 30 days of the date your case is assigned a docket\nnumber. If mailing payment, please send a certified check, bank check, or money order to:\nCashiers Room 260, 500 Pearl Street, New York, NY 10007.\n• Your payment must include the docket number, which you can learn by calling (212)\n805-0175.\n• If you have not consented to e-service, your docket number will also be mailed to you,\nat the address provided on the complaint, in a form order that will include payment instructions.\nIf you do not make payment within 30 days of the date a docket number is assigned to your\ncase, the action will be dismissed without prejudice.\n• If you cannot pay the filing fees and want to request that the court waive the filing fees,\nyou must email an ll,pplicatlon to proceed in torma pQJJ!W]i.\nFiling Documents in an Existing Case by Email:\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 59 of 61\nIMPORTANT INFORMATION, PLEASE REVIEW\nFrom Pro Se Filing <pro_seJiling@nysd.uscourts.gov>\nTo\nDate\nIMPORTANT INFORMATION, PLEASE REVIEW\nYour email has been received by the Pro Se Intake Unit of the United States District Court for the\nSouthern District of New York. (This is not the United States Bankruptcy Court.)\nDocuments from pro se litigants that meet the required standards for electronic filing will be filed and\nwill appear on the ECF docket within two business days. of receipt (see required standards below). If\n'\nyou send your document by email and it is accepted for filing, you should not deliver a hard copy\nversion to the court.\nRequirements for Filing a New Action by Email:\n• Documents must be attached to the email in PDF format, no larger than 15. megabytes;\n• The complaint must be signed by the filing party;\n• Fee requirements and instructions:\n• Please note that your complaint will not be reviewed until the court receives\npayment of the filing fees.\n• Payment must be made within 30 days of the date your case is assigned a docket\nnumber. If mailing payment, please send a certified check, bank check, or money order to:\nCashiers Room 260, 500 Pearl Street, New York, NY 10007.\n• Your payment must include the docket number, which you can learn by calling (212)\n805-0175.\n• If you have not consented to e-service, your docket number will also be mailed to you,\nat the address provided on the complaint, in a form order that will include payment instructions.\nIf you do not make payment within 30 days of the da_te a docket number is assigned to your\ncase, the action will be dismissed without prejudice.\n• If you cannot pay the filing fees and want to requestthat the court waive the filing fees,\nin\nyou must email an i!P-P-lication to proceed fm{lQ!J/2£fil.,\nFiling Documents in an Existing Case by Email:\n\nCase: 26-1626, 06/12/2026, DktEntry: 1.1, Page 60 of 61\nRespectfully submitted\nThe undersigned, Anna , declares under penalty of perjury the foregoing is\ntrue and correct to the best of Petitioner's knowledge and belief.\nSignature: ~\nCertificate of Service\nPetitioner certifies that on June 9th 2026, Petitioner submitted this Writ of Mandamus filing\n,\nto the following parties:\nVia USPS:\nThe Hon. Analisa Torres, SONY District Court\n500 Pearl Street, New York, NY 10007 -1312\nNathan Rehn\nUnited States Attorney's Office for the SONY\n26 Federal Plaza, 37th Floor\nNew York, NY 10278\nVia email only:\nCounsels for the Defendant\n• msarafa@sarafalaw.com\n• jdratel@dratellewis.com\n• jkaley@doarlaw.com\nSignature: - - -\n\nCase: 26-1626, 06/12/2026, MDktEntAry: 1.1I, PLage 61 of 61\n~ERVIC~-® \\\n'--\"'\"•~ \"-~\n.,\n·.,\n\"\"'\"-~. '\n\"'apply).'\n,rnational destinations.\n\\ FR\n••\n,.;:;,t\nl\n-0~w\n·i: :./ -~ /ood7\n' ,1... •\nC\nI £\" \" - '\"!- t✓ w'\"\n►>\n\\1• \\ '\", _ \" -,, a<i\"> · ,Dc · -o , • .} it,;:} .~;e -~ -1 ..i . i.~O\n' --~ ~ ·~•,.'4'~ • 'l_ ~ ~ - - --\n:a·~-;;..,\"~_:.. ·- ,\n·r· • · ·\n1 . ,:(_\ni'\n~ n:.-\n\\ ,i· --- ~NAT\\ONA • . ,'.\"\\';......\n~;J.:'\"\n1,1, I - .\niO:\n\\,._,_~ _-· I\nEXP~;TE~ ~ELIVERY DAY: 06/12/26\nI!' __ _.,,. 1\n~ ~,-- ~\n(>~k\nI\n\\\nUS t,,Oc$1( ~PP44\n\\\n&vv1\nU rvLA./4V\ne1\n~q\n4 \\) Fol\niitCvrtL-\n~ _j\n7\n'(uflLI >-JY (\noov\n\\,\n\\\n'\n~r\\NSURED\nI","body_zh":null,"key_entities":[],"ecf_references":[],"word_count":11397,"status":"published","published_at":null,"created_at":null,"updated_at":"2026-07-07 13:44:16"}