{"id":"court_ctb_2292_53","court":"CTB","case_no":"22-50073","doc_number":2292,"sub_number":53,"doc_type":"EXHIBIT","filed_date":"2023-10-26","title":"Exhibit 53 EXHIBIT B","summary_zh":null,"summary_en":null,"body_en":"#### **Exhibit 53**\n\n# **EXHIBIT B**\n\n# **Exhibit 21**\n\n## Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 4 of Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 3 of 51 52\n\n\n\nSeptember 11, 2023\n\n800.211.DEPO (3376) EsquireSolutions.com\n\nYVer1f\n\nHING CHI NGOK· Highly Confidential\n\n| | Page 5 | | Page 7 |\n|----------|-------------------------------------------------------------------------------------|--------|--------------------------------------------------------------------|\n| 1 | VIDEOGRAPHER: This is Tape No. 1 to the | 1
2 | ECHO LIM, having first been duly
sworn, interpreted as follows: |\n| 2 | videotaped deposition of Hing Chi Ngok in the | 3 | HING CHI NGOK, having first been duly |\n| 3 | matter of Despins, Kwok (sic) v. Greenwich | 4 | sworn, was deposed and testified as follows: |\n| 4
5 | Land, et al., being heard before the United
States Bankruptcy Court, District of | 5 | |\n| 6 | Connecticut, Bridgeport Division, Case | 6 | DIRECT EXAMINATION |\n| 7 | No. 22-50073. | 7 | BY MR. LUFT: |\n| 8 | This deposition is being held at Meister | 8 | Q Good morning, Ms. Ngok. How are you? |\n| 9 | Seelig & Fein on 9/11/2023 at 10:22 a.m. My | 9 | A Good. Thank you. |\n| 10 | name is Debbie O'Toole. I'm the videographer. | 10 | Q Ms. Ngok, I wanted to confirm that you |\n| 11 | The court reporter is Debbie Gentile. | 11 | understood you're appearing both as an individual |\n| 12 | Counsel, will you please introduce | 12 | deponent today and as the corporate representative |\n| 13 | yourselves and affiliations? And the witness | 13 | for Greenwich Land, correct? |\n| 14 | will be sworn. | 14 | A Yes. |\n| 15 | MR. LUFT: Good morning. My name is | 15 | MR. LUFT: And I'll ask the court reporter |\n| 16 | Avi Luft. I'm with the law firm of | 16 | to mark as Exhibit 1 a Chapter -- a copy of the |\n| 17 | Paul Hastings. I represent the Chapter 11 | 17 | Chapter 11 trustee's notice of deposition to |\n| 18 | trustee, Luc A. Despins. With me are my | 18 | Hing Chi Ngok. |\n| 19 | colleagues, Doug Barron and Luyi Song. | 19 | (Exhibit 1 was marked for I.D.) |\n| 20 | MR. MAJOR: Good morning. Chris Major, | 20 | (A discussion was held off the |\n| 21 | Meister Seelig & Fein. We represent the | 21 | stenographic record.) |\n| 22 | defendants in this adversary proceeding, | 22 | THE WITNESS: I am not able to read this. |\n| 23 | Ms. Guo and Greenwich Land, LLC, and we're | 23 | BY MR. LUFT: |\n| 24 | representing the witness in this deposition. | 24 | Q I understand. |\n| 25 | MR. INTRATER: Good morning. | 25 | Ms. Ngok, I've handed you what is a copy |\n| | | | |\n| | | | |\n| | Page 6 | | Page 8 |\n| 1 | Zach Intrater, Brafman & Associates. I | 1 | of the Chapter 11's notice of deposition to Hing Chi |\n| 2 | represent Ms. Guo in this deposition. | 2 | Ngok. Have you ever seen this document before? |\n| 3 | COURT REPORTER:
Usual stips? | 3 | MR. MAJOR: Objection to form. |\n| 4 | MR. LUFT:
I don't know what they are, so | 4 | THE WITNESS: I am not able to recognize |\n| 5 | we're going to just go until we figure it out. | 5 | it. I cannot read English and I don't |\n| 6 | MR. MAJOR:
Well, I'd like to, just for -- | 6
7 | understand the content of this document.
BY MR. LUFT: |\n| 7 | so we can get through this deposition, I'd like | 8 | Q Okay. |\n| 8 | to have a stipulation that all objections | 9 | MR. LUFT: I'm going to mark as Ngok |\n| 9 | except as to the form of the question are | 10 | Deposition Exhibit 2 a copy of the Chapter 11 |\n| 10 | reserved.
This way we don't have to hash out | 11 | trustee's notice of deposition of Greenwich |\n| 11 | every potential objection. | 12 | Land, LLC, pursuant to Federal Rule of Civil |\n| 12 | MR. LUFT:
That's fine.
That's my | 13 | Procedure 30(b)(6). |\n| 13 | understanding of the rules anyway.
My point | 14 | (Exhibit 2 was marked for I.D.) |\n| 14 | was not that there were none, just it's what | 15 | BY MR. LUFT: |\n| 15 | they are. | 16 | Q Ms. Ngok, I've handed you what has been |\n| 16 | MR. MAJOR:
Okay. | 17 | marked as Exhibit 2, which is a copy of the notice |\n| 17
18 | MR. LUFT:
And --
COURT REPORTER:
Please raise your | 18 | of deposition for Greenwich Land, LLC. Have you |\n| | | 19 | ever seen this document before? |\n| 19
20 | right --
MR. LUFT:
Sorry. | 20 | MR. MAJOR: Objection to form. |\n| 21 | Just so it's clear for the record, this | 21 | THE WITNESS: I do not know what you mean. |\n| 22 | deposition is of Ms. Hing Chi Ngok and of | 22 | INTERPRETER: Can the interpreter |\n| 23 | Greenwich Land.
So it's both defendants. | 23 | reinterpret the question? That's what Ms. Ngok |\n| 24 | | 24 | is requesting. |\n| 25 | | 25 | MR. LUFT: Okay. My only question is |\n\n\n\n| | Page 9 | | Page 11 |\n|----|------------------------------------------------------|----|------------------------------------------------------|\n| 1 | whether she has seen this document before. | | |\n| 2 | (Interpreter speaking Mandarin.) | | |\n| 3 | MR. MAJOR: Objection to form. | | |\n| 4 | THE WITNESS: I don't understand this | | |\n| 5 | document. | | |\n| 6 | BY MR. LUFT: | | |\n| | | | |\n| 7 | Q Ms. Ngok, were you provided a translation | | |\n| 8 | of the notice of deposition by your counsel setting | | |\n| 9 | out in Chinese what the deposition topics were for | | |\n| 10 | today's deposition on behalf of Greenwich Land, LLC? | | |\n| 11 | MR. MAJOR: Objection to form. Instruct | | |\n| 12 | the witness not to answer on the grounds of | | |\n| 13 | privilege. | 13 | BY MR. LUFT: |\n| 14 | THE WITNESS: Okay. | 14 | Q Ms. Ngok, I am going to ask you a series |\n| 15 | BY MR. LUFT: | 15 | of questions, just like I did last time. If for any |\n| 16 | Q Are you going to follow your counsel's | 16 | reason you do not understand my question, will you |\n| 17 | instruction? | 17 | let me know? |\n| 18 | A Correct. | 18 | A Okay. |\n| 19 | Q Ms. Ngok, are you prepared to testify on | 19 | Q If for -- and if -- can we have an |\n| 20 | the 17 topics listed in the Greenwich Land | 20 | agreement that if you do not tell me that you don't |\n| 21 | deposition notice? | 21 | understand my question, then I can assume you did |\n| 22 | A Yes. | 22 | understand it? |\n| 23 | Q Okay. You can put that aside. | 23 | MR. MAJOR: Objection to form. |\n| 24 | Ms. Ngok, as you know, I took your | 24 | THE WITNESS: I don't quite understand |\n| 25 | deposition on January 5, 2023, correct? | 25 | what you mean by that. Can you explain? |\n| | | | |\n| 1 | Page 10
A In January, yes. I remember. | 1 | Page 12
BY MR. LUFT: |\n| 2 | Q The rules are the same for this | 2 | Q Sure. If for -- if I ask you a question |\n| 3 | deposition. But if you'll indulge me, I'll just go | 3 | and you don't tell me that you don't understand it, |\n| | | | |\n| 4 | over a couple of them, okay? | 4 | is it fair for me to assume that you do understand |\n| 5 | A Yes, please. | 5 | it? |\n| 6 | Q Ms. Ngok, you understand that you're | 6 | A No. If I didn't understand a question, |\n| 7 | testifying under oath today? | 7 | you can't assume that I understand a question. |\n| 8 | A Of course. | 8 | Q Thank you. That's not what I was saying, |\n| 9 | Q You understand that means you have to | 9 | so this is a perfect example. Let's start again. |\n| 10 | testify truthfully? | 10 | If you don't understand my question, will |\n| 11 | A Correct. | 11 | you tell me? |\n| 12 | Q And you understand that you may not omit | 12 | A I will not. If I don't understand your |\n| 13 | information that you know that is called for by the | 13 | question, I will not tell you, because I didn't |\n| 14 | question, correct? | 14 | understand. |\n| 15 | A Of course. | 15 | Q Will you tell me that you don't understand |\n| | | 16 | my question? |\n| | | 17 | A Yes, of course. |\n| | | 18 | Q And if I ask you a question and you do not |\n| | | 19 | tell me that you don't understand, can I assume that |\n| | | 20 | you do understand my question? |\n| | | 21 | MR. MAJOR: Objection to form. |\n| | | 22 | THE WITNESS: Of course. That works. |\n| | | 23 | BY MR. LUFT: |\n| | | 24 | Q Great. Okay. |\n| | | 25 | Ms. Ngok, as we've discussed, you're |\n| | | | |\n| | | | |\n\n| | Page 13 | | Page 15 |\n|----|---------------------------------------------------------|----|-------------------------------------------------------|\n| 1 | appearing on behalf of yourself and for the entity | | |\n| 2 | Greenwich Land today? | | |\n| 3 | A Yes. | | |\n| 4 | Q If in answering a question your answer | | |\n| 5 | would differ from what -- your answer as an | | |\n| 6 | individual, as opposed to your answer on behalf of | | |\n| 7 | Greenwich Land, will you let me know? | | |\n| | | 8 | Q Other than Mr. Major and Mr. Intrater, |\n| 8 | A Yes. | | |\n| 9 | Q Ms. Ngok, what did you do to prepare for | 9 | have you discussed this deposition with anyone else? |\n| 10 | your deposition today? | 10 | MR. MAJOR: Objection to form. |\n| 11 | A I did. I prepared with my attorneys. | 11 | THE WITNESS: No. |\n| 12 | Q And who are your attorneys today? | 12 | BY MR. LUFT: |\n| 13 | THE WITNESS: I'm sorry, Gentlemen. I | 13 | Q Other than Mr. Intrater and Mr. Major, |\n| 14 | can't pronounce your names. | 14 | have you discussed this case with anyone else? |\n| 15 | But these two gentlemen sitting right here | 15 | MR. MAJOR: Objection to form. |\n| 16 | (indicating). | 16 | THE WITNESS: No. |\n| 17 | BY MR. LUFT: | 17 | BY MR. LUFT: |\n| 18 | Q Mr. Major and -- | 18 | Q In preparing for this deposition, did you |\n| 19 | MR. LUFT: Intrater? Is that | 19 | review any documents? |\n| 20 | MR. INTRATER: That's great. Perfect. | 20 | A I did. |\n| 21 | THE WITNESS: I'm sorry. I don't have any | 21 | Q What documents did you review? |\n| 22 | mental note of any English name. Sorry about | 22 | A The same documents I review for the last |\n| 23 | that. | 23 | deposition. |\n| 24 | MR. LUFT: That's fine. | 24 | Q Can you remind me what documents those |\n| 25 | For the record can we agree that she has | 25 | were? |\n| | | | |\n| 1 | Page 14
pointed to Mr. Major and Mr. Intrater as her | 1 | Page 16
A Some -- something like some sort of bank |\n| 2 | counsel who she met with? | 2 | documents. But to be very frank with you, I don't |\n| | | | |\n| 3 | MR. MAJOR: Yes. | 3 | even understand them. |\n| 4 | MR. LUFT: Okay. | 4 | Q Do you recall what bank documents they |\n| 5 | THE WITNESS: (In English) Sorry about | 5 | were? |\n| 6 | that. | 6 | A I can't remember. |\n| 7 | MR. LUFT: That's okay. | 7 | Q Other than preparing for this deposition, |\n| 8 | THE WITNESS: Okay. | 8 | had you ever seen these bank documents before? |\n| 9 | BY MR. LUFT: | 9 | A No. |\n| 10 | Q How many times did you meet with them in | 10 | Q Were they bank documents related to your |\n| 11 | preparation for this deposition? | 11 | personal bank accounts? |\n| 12 | A Twice. | 12 | MR. MAJOR: Objection to form. |\n| 13 | Q When did you meet with them? | 13 | THE WITNESS: No. |\n| 14 | A I can't remember specifically when, but it | 14 | BY MR. LUFT: |\n| 15 | happens within a month. | 15 | Q Were they bank accounts related to |\n| 16 | Q How long did you meet with them? | 16 | Greenwich Land's bank accounts? |\n| 17 | A It could range from one to two hours or | 17 | MR. MAJOR: Objection to form. |\n| 18 | two to three hours. | 18 | THE WITNESS: They are not statements. I |\n| 19 | Q When you met with your attorney, | 19 | don't know what they are. I am not even -- I'm |\n| 20 | Mr. Intrater or Mr. Major, was there anyone else | 20 | not able to tell what they are. |\n| 21 | present? | 21 | BY MR. LUFT: |\n| 22 | A Interpreters -- interpreter. | 22 | Q Can you give me your best description of |\n| 23 | INTERPRETER: Sorry. | 23 | those bank documents? |\n| 24 | BY MR. LUFT: | 24 | A Okay. I don't know if they are even a |\n| | | 25 | document -- they are even a document. I have seen |\n| | | | |\n\n\n\nSeptember 11, 2023\n\n800.211.DEPO (3376) EsquireSolutions.com\n\nYVer1f\n\nHING CHI NGOK· Highly Confidential\n\n| 1 | Page 17
them. I can't recall. I can't tell the content of | 1 | Page 19
MR. MAJOR: Objection to form. Instruct |\n|----------|-------------------------------------------------------------------------------------------------|----------|---------------------------------------------------------------------------------------|\n| 2 | it. | 2 | the witness not to answer on the grounds of |\n| 3 | Q But they were documents that you looked at | 3 | privilege. |\n| 4 | to prepare for this deposition? | 4 | MR. LUFT: On what grounds can that be |\n| 5 | MR. MAJOR: Objection to form. | 5 | privileged? I'm asking just the name of who's |\n| 6 | THE WITNESS: Correct. | 6 | the person who made the decision. |\n| 7 | MR. LUFT: Mr. Major, I don't believe | 7 | MR. MAJOR: The decision that you're |\n| 8 | we've received any bank documents. Have they | 8 | referring to -- first of all, you're |\n| 9 | been -- the documents the witness is referring | 9 | presupposing that the decision was the decision |\n| 10 | to, have they been produced to us? | 10 | of Greenwich Land. But the contemplation of |\n| 11 | MR. MAJOR: I don't know what documents | 11 | hiring or separating from counsel is |\n| 12 | the witness is specifically referring to, but | 12 | privileged. |\n| 13 | we have produced bank records to you, | 13 | MR. LUFT: I'm not asking about the |\n| 14 | specifically from The Bank of Princeton. I | 14 | content; I just want to know who was the person |\n| 15 | know that my firm handled that production. I | 15 | who made the decision. That's not privileged. |\n| 16 | know the law firm of Updike, Kelly & Spellacy, | 16 | It doesn't call for legal advice or anything |\n| 17 | I believe, produced some bank records to you in | 17 | else. |\n| 18 | advance of the just closed Rule 2004 exam. I | 18 | MR. MAJOR: The decision of either hiring |\n| 19 | assume that's what the witness is referring to, | 19 | or separating from counsel is a privileged |\n| 20 | but I don't know. | 20 | matter. |\n| 21 | MR. LUFT: Okay. I'll just ask that on a | 21 | MR. LUFT: Correct, but the person who -- |\n| 22 | break you confer with her, and if there are | 22 | the name of the person who decided that is not |\n| 23
24 | documents that we haven't received yet, if you
just let us know and produce them, okay? | 23
24 | privileged.
MR. MAJOR: To the extent it -- the |\n| 25 | MR. MAJOR: Yes. And I do not think there | 25 | question necessarily calls for discussions with |\n| | | | |\n| | | | |\n| | Page 18 | | Page 20 |\n| 1 | are documents that we have that you don't have | 1 | counsel. |\n| 2
3 | yet, but I will certainly triple-check that
during a break. | 2
3 | MR. LUFT: No, it just calls for the name,
the name of the person. She is here as |\n| 4 | MR. LUFT: Terrific. | 4 | Greenwich Land's representative; I'm free to |\n| 5 | BY MR. LUFT: | 5 | ask her who's the person who made the decision. |\n| 6 | Q Other than the documents you've referred | 6 | That's not a privileged question. |\n| 7 | to as the \"bank documents,\" are there any other | 7 | MR. MAJOR: You can ask questions about |\n| 8 | documents you looked at to prepare for this | 8 | decisions that Greenwich Land made on other |\n| 9 | deposition? | 9 | matters, but not on counsel. |\n| 10 | A There must be some, but I can't remember | 10 | MR. LUFT: Okay. I disagree with you, I |\n| 11 | what they are. | 11 | think you're obstructing, and you haven't given |\n| 12 | Q When was the last time you reviewed these | 12 | me any explanation why the name of an |\n| 13 | documents? | 13 | individual calls for the provision of legal |\n| 14 | A Probably approximately three weeks ago, | 14 | advice. |\n| 15 | but I don't remember specifically when. | 15 | BY MR. LUFT: |\n| 16 | Q Okay. Ms. Ngok, when I deposed you in | 16 | Q Ms. Ngok, are you going to follow your |\n| 17 | January, you were represented by a different lawyer | 17 | counsel's instruction? |\n| 18 | from a different law firm, correct? | 18 | A Correct. |\n| 19 | A Correct. | 19 | Q Ms. Ngok, were you the person who made the |\n| 20 | Q And that was Mr. Goldstein from the Updike | 20 | decision to replace Updike Kelly with Mr. Major's |\n| 21 | Kelly firm, correct? | 21 | firm? |\n| 22 | A I don't remember. | 22
23 | MR. MAJOR: Objection to form. Instruct
the witness not to answer on the grounds of |\n| 23
24 | Q Who made the decision at Greenwich Land to
change counsel from Updike Kelly to Mr. Major's | 24 | privilege. |\n| 25 | firm? | 25 | |\n\n\n\n| | Page 21 | | Page 23 |\n|----|------------------------------------------------------|----|------------------------------------------------------|\n| 1 | BY MR. LUFT: | 1 | before you signed the supplemental responses to the |\n| 2 | Q Ms. Ngok, are you going to follow your | 2 | interrogatories? |\n| 3 | counsel's direction? | 3 | A I did. |\n| 4 | A Correct. | 4 | Q And before signing did you agree that all |\n| 5 | Q Ms. Ngok, I'm going to ask the court | 5 | the information included in the document was |\n| 6 | reporter to mark as Ngok Deposition Exhibit 3 a copy | 6 | accurate and true? |\n| 7 | of defendant Greenwich Land, LLC's supplemental | 7 | MR. MAJOR: Objection to form. |\n| 8 | responses and objections to the first set of | 8 | THE WITNESS: I believe so. |\n| 9 | interrogatories by plaintiff Luc Despins, the | 9 | BY MR. LUFT: |\n| 10 | Chapter 11 trustee. | 10 | Q Ms. Guo, if we look at response to |\n| 11 | (Exhibit 3 was marked for I.D.) | | |\n| | | 11 | Interrogatory No. 1 -- |\n| 12 | BY MR. LUFT: | 12 | INTERPRETER: Ms. -- did you say, |\n| 13 | Q Ms. Ngok -- | 13 | \"Ms. Guo\"? |\n| 14 | (A discussion was held off the | 14 | MR. LUFT: Sorry. Ms. Ngok. |\n| 15 | stenographic record.) | 15 | INTERPRETER: Sorry. Okay. |\n| 16 | BY MR. LUFT: | 16 | THE WITNESS: Okay. |\n| 17 | Q Ms. Ngok, I've put in front of you as | 17 | BY MR. LUFT: |\n| 18 | marked as Exhibit 3 a document titled \"Defendant | 18 | Q -- there's a sentence that says \"Greenwich |\n| 19 | Greenwich Land, LLC's Supplemental Responses and | 19 | Land's sole purpose is to own a residential property |\n| 20 | Objections to the First Set of Interrogatories by | 20 | in Greenwich, Connecticut.\" |\n| 21 | Plaintiff Luc Despins,\" the Chapter 11 trustee. Do | 21 | A Correct. |\n| 22 | you see that? | 22 | Q Is that true? |\n| 23 | MR. MAJOR: Objection to form. | 23 | A Correct. |\n| 24 | THE WITNESS: Yes, I see it. | 24 | Q So when you say \"Greenwich Land's sole |\n| 25 | | 25 | purpose is to own a residential property in |\n| | | | |\n| | | | |\n| | Page 22 | | Page 24 |\n| 1 | BY MR. LUFT: | 1 | Greenwich, Connecticut,\" what do you mean? |\n| 2 | Q If you turn to the last page of the | 2 | MR. MAJOR: Objection to form. |\n| 3 | document, you'll see a signature line for Greenwich | 3 | THE WITNESS: I don't understand this |\n| 4 | Land. It says by Hing Chi Ngok, \"Title: Sole | 4 | question. Can you please clarify? |\n| 5 | Member.\" | 5 | BY MR. LUFT: |\n| 6 | INTERPRETER: Sorry. | 6 | Q My question is simply there's a statement |\n| 7 | THE WITNESS: Yes. | 7 | in the interrogatory, and I just want to understand |\n| 8 | BY MR. LUFT: | 8 | what Greenwich Land meant by that statement. |\n| 9 | Q Do you see that, Ms. Ngok? | 9 | MR. MAJOR: Objection to form. |\n| 10 | A I see it. | 10 | THE WITNESS: Can you please tell me which |\n| 11 | Q And whose signature is that? | 11 | statement? |\n| 12 | A It looks like my signature, but I cannot | 12 | BY MR. LUFT: |\n| 13 | be certain that it is mine. | 13 | Q Sure. It is on the response to |\n| 14 | Q The date of this document is September 9, | 14 | Interrogatory No. 1. There's a sentence that says |\n| 15 | 2023, two days ago. | 15 | \"Greenwich Land's sole purpose is to own a |\n| 16 | A Two days ago? | 16 | residential property in Greenwich, Connecticut.\" |\n| 17 | Q Yes. | 17 | A Correct. |\n| 18 | Do you recall signing responses -- | 18 | Q And my under -- my question is what does |\n| 19 | interrogatory responses two days ago? | 19 | Greenwich Land mean by that statement? |\n| 20 | A I believe so. | 20 | MR. MAJOR: Objection to form. |\n| 21 | Q And the document indicates that you were | 21 | THE WITNESS: I don't know what you mean |\n| 22 | provided a translation of this English document into | 22 | by that. This company owns properties, isn't |\n| 23 | Mandarin; is that correct? | 23 | it? |\n| 24 | A Correct. | | |\n| 25 | Q Did you read that Mandarin translation | | |\n\n\n\n#### Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 9 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 10 of 52\n\n\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 10 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 11 of 52\n\nSeptember 11, 2023\n\n800.211.DEPO (3376) EsquireSolutions.com\n\nYVer1f\n\nHING CHI NGOK· Highly Confidential\n\n| 1 | Page 29
THE WITNESS: I don't know about that too. | 1 | Page 31
discussing? |\n|----------|--------------------------------------------------------------|----------|-------------------------------------------------------------------------------------------|\n| 2 | BY MR. LUFT: | 2 | MR. MAJOR: Objection to form. |\n| 3 | Q Since Greenwich Land has been founded, | 3 | THE WITNESS: I do not know. |\n| 4 | who -- what individuals have had the right to spend | 4 | BY MR. LUFT: |\n| 5 | money on behalf of Greenwich -- or let me strike | 5 | Q Do you have any idea where Greenwich Land |\n| 6 | that. | 6 | gets the money from that you use to pay for personal |\n| 7 | Since Greenwich Land has been founded, | 7 | expenses unrelated to the two houses we've been |\n| 8 | what individuals have had the right to spend money | 8 | discussing? |\n| 9 | from Greenwich Land accounts? | 9 | MR. MAJOR: Objection to form. |\n| 10 | MR. MAJOR: Objection to form. | 10 | THE WITNESS: I do not know. |\n| 11 | THE WITNESS: I don't know. | 11 | BY MR. LUFT: |\n| 12 | BY MR. LUFT: | 12 | Q Where does Greenwich Land get the money |\n| 13 | Q Ms. Ngok, do you have the right to spend | 13 | from that it uses to pay for expenses related to the |\n| 14 | Greenwich Land's money? | 14 | two houses we've been discussing? |\n| 15 | MR. MAJOR: Objection to form. | 15 | MR. MAJOR: Objection to form. |\n| 16 | THE WITNESS: I believe I do. | 16 | INTERPRETER: Can the interpreter |\n| 17 | BY MR. LUFT: | 17 | reinterpret? |\n| 18 | Q What are you allowed to spend Greenwich | 18 | THE WITNESS: I do not know. |\n| 19 | Land's money on? | 19 | BY MR. LUFT: |\n| 20 | MR. MAJOR: Objection to form. | 20 | Q Who at Greenwich Land would know where it |\n| 21 | THE WITNESS: It's just like the family | 21 | gets the money it spends? |\n| 22 | day-to-day expenditures. | 22 | MR. MAJOR: Objection to form. |\n| 23 | BY MR. LUFT: | 23 | THE WITNESS: I do not know. |\n| 24 | Q Related to the properties or any | 24 | BY MR. LUFT: |\n| 25 | expenditures related to the family? | 25 | Q Who at Greenwich Land would know who |\n| | | | |\n| | Page 30 | | Page 32 |\n| 1 | MR. MAJOR: Objection to form. | 1 | provides the money that goes into Greenwich Land's |\n| 2 | THE WITNESS: It's like the family | 2 | bank accounts? |\n| 3 | expenditure. For instance, like landscaping, | 3 | MR. MAJOR: Objection to form. |\n| 4 | utilities. | 4 | THE WITNESS: I'm not clear about that. |\n| 5 | BY MR. LUFT: | 5 | BY MR. LUFT: |\n| 6 | Q How about personal expenses not related to | 6 | Q Do you know who provides the funds that |\n| 7 | upkeep of the house for -- let me just stop there. | 7 | have been placed into Greenwich Land's bank accounts |\n| 8 | MR. MAJOR: Objection to form. | 8 | since its -- since they've been open till today? |\n| 9 | THE WITNESS: Sometime, yes. | 9 | MR. MAJOR: Objection to form. |\n| 10 | BY MR. LUFT: | 10 | THE WITNESS: I do not know. |\n| 11 | Q What personal expenses not related to the | 11 | BY MR. LUFT: |\n| 12 | house do you spend Greenwich Land money on? | 12 | Q Ms. Guo, do any -- sorry. Let me strike |\n| 13 | MR. MAJOR: Objection to form. | 13 | that. Let's get some clarity. |\n| 14 | THE WITNESS: Nothing too specific. | 14
15 | Ms. Ngok, my understanding is that your
last name is spelled N-G-O-K; is that correct? |\n| 15
16 | BY MR. LUFT:
Q Give me your best recollection of personal | 16 | A Correct. |\n| 17 | expenses not related to the upkeep of the two houses | 17 | Q In response -- if we look at Exhibit 3, in |\n| 18 | you've mentioned for which you've used Greenwich | 18 | response to our interrogatories, all the references |\n| 19 | Land money. | 19 | are either to a \"Ms. Guo\" or a \"Mrs. Guo.\" So my |\n| 20 | MR. MAJOR: Objection to form. | 20 | first question is are you -- is the references to |\n| 21 | THE WITNESS: I don't remember. | 21 | \"Mrs. Guo\" to be understood to be a reference to |\n| 22 | BY MR. LUFT: | 22 | you, Ms. Ngok? |\n| 23 | Q What's the source of Greenwich Land's | 23 | A Correct. |\n| 24 | money that is used to pay for personal expenses not | 24 | Q And are the references to \"Ms. Guo\" also |\n| 25 | related to the upkeep of the two houses we've been | 25 | intended to be a reference to you, Ms. Ngok? |\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 11 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 12 of 52\n\nPage 33 1 A Correct. 2 Q Ms. Guo -- sorry. Let me strike that. 3 (Witness speaking Mandarin.) 4 INTERPRETER: She said she couldn't hear 5 me clear. 6 You okay? 7 (A discussion was held off the 8 stenographic record.) 9 BY MR. LUFT: 10 Q Ms. Ngok, have you ever received money 11 from an entity called Hudson Diamond New York? 12 A I don't remember. 13 Q I'm going to ask the court reporter to 14 mark as Ngok Deposition Exhibit 4 a document Bates 15 stamped 19 (Exhibit 4 was marked for I.D.) 20 MR. MAJOR: Objection to form. To the 21 extent that the question is to ask the witness 22 to read the document and state whether she can 23 identify it, I just want to note for the 24 record, she does not read English so would not 25 have the ability to answer that question. Page 34 1 MR. LUFT: Why don't you let me ask my 2 question and then object to it? 3 MR. MAJOR: Okay. I just didn't know if 4 you -- if your statement was a question. It's not a 7 question, right? 8 BY MR. LUFT: 17 BY MR. LUFT: 18 Q Ms. Ngok -- 19 A Yes. 20 Q -- 22 MR. MAJOR: Objection to form. 23 THE WITNESS: I do not know. 24 BY MR. LUFT: 25 Q Page 35 1 2 MR. MAJOR: Objection to form. 3 THE WITNESS: I do not know. 4 BY MR. LUFT: 5 Q Tell me everything you know about Hudson 6 Diamond New York. 7 A I've never heard of this company before. 8 Q 11 MR. MAJOR: Objection to form. 16 BY MR. LUFT: 19 A Yes. 20 Q 22 MR. MAJOR: Objection to form. 23 THE WITNESS: Page 36 1 MR. LUFT: Okay. Why don't we take a 2 short break? 'Cause I'm going to go for a 3 while after that. 4 MR. MAJOR: Sure. 5 VIDEOGRAPHER: Okay. We're off the 6 record. The time is 11:25. 7 (A recess was taken.) 8 VIDEOGRAPHER: We're back on the record. 9 The time is 11:46. 10 (A discussion was held off the 11 stenographic record.) 12 BY MR. LUFT: 22 MR. LUFT: The document's upside-down for 23 the witness. 24 BY MR. LUFT: 25 Q Ms. Ngok, before you Exhibit 5, as I said,\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 12 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 13 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 13 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 14 of 52\n\n| Page 41 | Page 43 |\n|-------------------------------------------------------------------------------|--------------------------------------|\n| | 1
BY MR. LUFT: |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | 14
BY MR. LUFT: |\n| | |\n| 16
BY MR. LUFT: | |\n| 17
Q Ms. Ngok, what address does Greenwich Land | |\n| 18
use for its banking? | |\n| 19
MR. MAJOR: Objection to form. | |\n| 20
THE WITNESS: I do not know. | |\n| 21
BY MR. LUFT: | |\n| | |\n| | |\n| | |\n| | |\n| Page 42 | Page 44 |\n| 1
INTERPRETER: She's asking a question. | 1
THE WITNESS: I do not remember. |\n| 2
THE WITNESS: I am unable to tell. | 2
BY MR. LUFT: |\n| 3
BY MR. LUFT: | |\n| 4
Q Ms. Ngok, what is the name of the company
5
that owns your home? | |\n| 6
A Let me think about it. | |\n| 7
Okay. I -- I struggle with spelling out | |\n| 8
the name of the company, so I used to use some | |\n| 9
Chinese similar pronunciation to write in Chinese | |\n| 10
character. It's called Guan Lei Chi. | |\n| 11
INTERPRETER: G-U-A-N L-E-I C-H-I. | |\n| 12
BY MR. LUFT: | |\n| 13
Q Is that in pinyin? Is that in pinyin? | |\n| 14
A Yes, it is pinyin. | |\n| 15
INTERPRETER: Ms. Guo -- Ms. Guo recorded | |\n| 16
it down in Chinese character; the interpreter | |\n| 17
made into pinyin. | |\n| 18
MR. LUFT: Okay. | |\n| 19
THE WITNESS: (In English) Sorry. | |\n| 20
BY MR. LUFT: | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 14 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 15 of 52\n\n| | Page 45
Page 47 |\n|-----------------------------------------------|-----------------------------------------------|\n| | 1 |\n| | 2
MR. MAJOR: There's no question. |\n| | 3
BY MR. LUFT: |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| 15
BY MR. LUFT: | |\n| 16
Q | |\n| | |\n| 18
MR. MAJOR: Objection to form. | |\n| 19
THE WITNESS: I do not know. | |\n| 20
MR. LUFT: Let's mark as Exhibit 8 a | |\n| 21
document bearing the Bates Stamp | |\n| 22 | 22
MR. LUFT: Okay. Let's mark as Exh bit 9 |\n| 23
(Exhibit 8 was marked for I.D.) | 23
a document |\n| 24
INTERPRETER: Thank you. | |\n| 25
MR. LUFT: Of course. | |\n| | |\n| 1
BY MR. LUFT: | Page 46
Page 48
1 |\n| | |\n| 2
Q And I'll represent to you that this is | |\n| 3
anothe | 3
(Exhibit 9 was marked for I.D.) |\n| | 4
BY MR. LUFT: |\n| | |\n| | |\n| | |\n| 8
A Okay. | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| 19
BY MR. LUFT: | |\n| 20
Q | |\n| | |\n| | |\n| | 23
Q |\n| | |\n| | |\n| | |\n| | |\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 15 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 16 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 16 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 17 of 52\n\n| Page 53 | Page 55 |\n|-----------------------------------------------|-------------------------------------------------------|\n| 1
MR. LUFT: Let's mark as Exhibit 11 a | 1
MR. MAJOR: Objection to form. |\n| 2
document bearing the Bates stamp | 2
THE WITNESS: I can't tell. I can't read. |\n| | 3
BY MR. LUFT: |\n| | 4
Q |\n| | |\n| | |\n| | |\n| | 7
MR. MAJOR: Objection to form. |\n| | 8
THE WITNESS: I do not know why. |\n| 9
(Exhibit 11 was marked for I.D.) | 9
BY MR. LUFT: |\n| 10
BY MR. LUFT: | 10
Q |\n| 11
Q | |\n| | |\n| | |\n| | |\n| | |\n| | 15
MR. MAJOR: Objection to form. |\n| 16
MR. MAJOR: Objection to form. | 16
THE WITNESS: I do not know. |\n| 17
THE WITNESS: I don't know. I can't -- I | 17
BY MR. LUFT: |\n| 18
don't recognize this document. | 18
Q |\n| 19
BY MR. LUFT: | |\n| 20
Q | |\n| | 21
MR. MAJOR: Objection to form and assumes |\n| | 22
a fact not established. |\n| 23
A I don't remember. | 23
MR. LUFT: What fact is that? |\n| 24
Q | 24
MR. MAJOR: Multiple facts in your |\n| | |\n| | 25
question -- alleged facts in your question. |\n| Page 54 | Page 56 |\n| 1 | 1 |\n| | |\n| | |\n| | |\n| 5
MR. MAJOR: Objection to form. | |\n| 6
THE WITNESS: | 6
MR. LUFT: We just walked through all the |\n| 7
BY MR. LUFT: | 7
documents, Mr. Major, showing that transfer, |\n| 8
Q Okay. | |\n| | 8
right? What more foundation could we have? |\n| | 9
MR. MAJOR: You're questioning a witness |\n| | 10
using English language documents even though |\n| | 11
you know she only reads Mandarin and trying to |\n| | 12
ask questions off of these documents. So I |\n| | 13
objected to the question; I didn't instruct the |\n| 14
MR. MAJOR: Objection to form. | 14
witness not to answer. But it's an improper |\n| 15
THE WITNESS: I -- I can't read these | 15
question, so I object to it. |\n| 16
words. | 16
MR. LUFT: Mr. Major, these are the bank |\n| 17
BY MR. LUFT: | 17
records and the statements of your client. |\n| 18
Q | 18
That they happen to be in English and you put |\n| | |\n| | 19
up a witness that doesn't speak English is your |\n| | 20
choice, but I can only use the records of the |\n| | 21
company. |\n| | 22
MR. MAJOR: I don't think these are |\n| | 23
documents we produced to you, based on the |\n| | 24
Bates numbering. |\n| | 25
MR. LUFT: You're right, Mr. Major. Some |\n| | |\n| | |\n| | |\n| | |\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 17 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 18 of 52\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 18 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 19 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 19 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 20 of 52\n\n| Page 65
1 | Page 67 |\n|-------------------------------------------------------|-----------------------------------------------------------------------------------------|\n| | 1
reason for the objection.
The other reason is |\n| | 2
she is the only person left at Greenwich Land, |\n| | 3
so if she doesn't know, the answer is obvious. |\n| | 4
But I can't -- I mean, I guess if you want |\n| | 5
me to, I could try to go back if you're asking |\n| 6
MR. MAJOR: Objection to form. | 6
me the basis for all of my objections. |\n| 7
THE WITNESS: This one (indicating), | 7
MR. LUFT:
No. |\n| 8
right? | 8
MR. MAJOR:
I'd have to -- there have been |\n| 9
BY MR. LUFT: | 9
a lot of questions. |\n| 10
Q Yes, ma'am. The first line and then the | 10
MR. LUFT:
I don't think objecting to |\n| 11
second line. | 11
questions because you think the answer is |\n| 12
A Yes, I see it. | 12
obvious is a basis for objecting to a |\n| | 13
question -- |\n| | 14
MR. MAJOR:
But the main reason for the |\n| | 15
objections is it was a nonsensical question: |\n| | 16
You're asking a witness who didn't know a fact |\n| | 17
if she knew who knew that fact so -- |\n| | 18
MR. LUFT:
Well, she's the corporate |\n| | 19
representative for the company; this is a house |\n| | 20
that the company alleges that it owns.
I don't |\n| | 21
think there's anything crazy about asking them |\n| | 22
who would know what law firm -- who hired the |\n| | 23
law firm that represented them. |\n| | 24
So we'll move on.
I understand -- I'm |\n| | 25
aware that you made an objection -- |\n| Page 66 | Page 68 |\n| | 1
MR. MAJOR: I wasn't instructing the
2
witness not to answer, and I try to be |\n| | 3
extremely judicious when I object so that I |\n| | 4
don't interfere with your transcript. And |\n| | 5
that's why I've been, as I said, very |\n| | 6
circumspect in my objections. |\n| | 7
MR. LUFT: Okay. |\n| | 8
MR. MAJOR: Or I should say \"concise\" in |\n| | 9
my objections. |\n| | 10
BY MR. LUFT: |\n| | 11
Q Ms. Ngok, what homes have you lived in |\n| | 12
since you've come to the United States? Meaning the |\n| | 13
addresses. |\n| 14
the witness answered the question that she did | 14
A When I first came to the United States, I |\n| 15
not know. We've given you interrogatory | 15
live in town. |\n| 16
responses explaining that Mrs. Guo is the only | 16
Q \"In town\" meaning Manhattan? |\n| 17
person left at Greenwich Land, and then your | 17
A Correct. |\n| 18
next question was who at Greenwich Land would | 18
Q At the Sherry Netherland hotel? |\n| 19
know what the law firm was? | 19
INTERPRETER: Sheraton? |\n| 20
And I objected to that question on a | 20
MR. LUFT: Sherry Netherland. |\n| 21
number of grounds, including you're asking a | 21
THE WITNESS: Correct. |\n| 22
witness who doesn't -- who just said she | 22
BY MR. LUFT: |\n| 23
doesn't know a fact if she knows who knows that | |\n| 24
fact that she doesn't know. So the question | |\n| 25
doesn't make a lot of sense to me. That's one | |\n| | |\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 20 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 21 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 21 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 22 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 22 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 23 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 23 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 24 of 52\n\n| Page 81 | Page 83 |\n|------------------------------------------------|--------------------------------------------------------------------------------------|\n| | 1
Q |\n| | |\n| | |\n| | 4
MR. MAJOR: Objection to form. |\n| | 5
THE WITNESS: I do not know why. |\n| | 6
BY MR. LUFT: |\n| | 7
Q |\n| | |\n| | |\n| | 10
MR. MAJOR: Objection to form. |\n| | 11
THE WITNESS: I do not know. |\n| | 12
BY MR. LUFT: |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | 21
MR. LUFT: And I will mark as Exhibit 14 a |\n| | 22
copy of a document Bates |\n| | |\n| | |\n| | |\n| | |\n| | |\n| Page 82 | Page 84 |\n| | 1 |\n| | |\n| | 3
(Exhibit 14 was marked for I.D.) |\n| | 4
BY MR. LUFT: |\n| | 5
Q |\n| | |\n| | |\n| | 8
MR. MAJOR: Objection to form. |\n| | 9
THE WITNESS: |\n| | 10
Okay. |\n| 11
BY MR. LUFT: | 11
BY MR. LUFT: |\n| 12
Q | 12
Q And if I ask you to turn to page ending in |\n| | 13
Bates number 42 -- |\n| | 14
MR. MAJOR: I don't think she'll know what |\n| | 15
a Bates number is. I can flip it for her or -- |\n| | 16
okay. |\n| 17
MR. MAJOR: Objection to form. | 17
INTERPRETER: I can help her. |\n| 18
THE WITNESS: This one (indicating), | 18
MR. MAJOR: Okay, please. |\n| 19
right? | 19
THE WITNESS: I'm on it. |\n| 20
BY MR. LUFT: | 20
BY MR. LUFT: |\n| 21
Q Yes, ma'am, the third one. | 21
Q |\n| 22
A No, it's this (indicating) -- | |\n| 23
Q Oh, sorry. Yes, correct, ma'am. You're | 23
MR. MAJOR: Objection to form. The |\n| 24
right. | |\n| 25
A Okay. I see it. | 24
witness can't read the words.
25
THE WITNESS: I'm not -- I can't read. I |\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 24 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 25 of 52\n\n| 1 | Page 85
really can't read. | 1
if Greenwich Land holds any ownership interest in | Page 87 |\n|----|-------------------------------------------------|--------------------------------------------------------|---------|\n| 2 | MR. LUFT: I understand. Not a problem. | 2
Saraca Media. | |\n| 3 | BY MR. LUFT: | 3
A I do not know. | |\n| | | 4
Q | |\n| | | | |\n| | | | |\n| | | | |\n| | | 8
MR. MAJOR: Objection to form. | |\n| | | 9
THE WITNESS: I am not sure about that. | |\n| | | 10
BY MR. LUFT: | |\n| | | 11
Q | |\n| | | | |\n| | | | |\n| | | | |\n| | | | |\n| | | 16
A I do not know. | |\n| | | 17
Q | |\n| | | | |\n| 19 | BY MR. LUFT: | | |\n| 20 | Q Ms. Ngok, do you have any ownership | | |\n| 21 | interest in Saraca Media? | | |\n| 22 | A No. I don't know. | | |\n| 23 | Q Ms. Ngok, do you have any ownership | | |\n| 24 | interest in Hudson Diamond New York? | | |\n| 25 | A What do you mean by that? | 25
MR. MAJOR: Objection to form. | |\n| | Page 86 | | Page 88 |\n| 1 | Q My question, I'll ask it in two ways: Do | 1
THE WITNESS: I don't know. | |\n| 2 | you personally, Ms. Ngok, have any ownership | 2
BY MR. LUFT: | |\n| 3 | interest in the entity named Hudson Diamond New | | |\n| 4 | York? | | |\n| 5 | A I don't remember. I don't even understand | | |\n| 6 | what he means by that. | | |\n| 7 | Q Ms. Ngok, does Greenwich Land have any | | |\n| 8 | ownership interest in Hudson Diamond New York? | | |\n| 9 | A I do not know. | | |\n| 10 | Q Does Greenwich Land have any ownership | | |\n| 11 | interest in Saraca Media? | | |\n| 12 | A I'm a little confused. I really don't | | |\n| 13 | know. | | |\n| 14 | Q That's okay. That's no worries. | | |\n| 15 | MR. MAJOR: If she's not well, she | | |\n| 16 | should -- you can take her out. | | |\n| 17 | MR. LUFT: Okay. Let's take a break. Off | | |\n| 18 | the record. Let's go off the record before -- | | |\n| 19 | VIDEOGRAPHER: The time is 3:20. Off the | | |\n| 20 | record. | 20
(Exhibit 15 was marked for I.D.) | |\n| 21 | (A recess was taken.) | 21
MR. LUFT: And would it be okay for us to | |\n| 22 | VIDEOGRAPHER: We're back on the record. | 22
just email a copy of it? | |\n| 23 | The time is 3:50. | 23
COURT REPORTER: Sure. | |\n| 24 | BY MR. LUFT: | 24
MR. LUFT: All right. So that's what | |\n| | Q Ms. Ngok, before we broke, I had asked you | 25
we'll do. | |\n| 25 | | | |\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 25 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 26 of 52\n\n| | Page 89 | | | | Page 91 |\n|----|----------------------------------------------------|----|---|-----------------------------------------|---------|\n| 1 | MR. MAJOR: I could also print it for you | 1 | | MR. MAJOR: Objection to form. | |\n| 2 | today. | 2 | | THE WITNESS: I don't remember. | |\n| 3 | MR. LUFT: That would be great too. I'm | 3 | | BY MR. LUFT: | |\n| 4 | happy to do it either way. | 4 | | Q Okay. No problem. | |\n| 5 | MR. MAJOR: Email it to me and I'll print | 5 | | | |\n| 6 | it. | | | | |\n| 7 | MR. LUFT: Perfect. Okay. | | | | |\n| 8 | BY MR. LUFT: | 8 | | A I don't remember. | |\n| | | | | | |\n| 9 | Q Ms. Ngok, earlier you told me that | 9 | Q | | |\n| 10 | Greenwich Land sold the house at 33 Ferncliff Road | | | | |\n| 11 | in Greenwich, Connecticut. Do you recall that? | | | | |\n| 12 | A Yes, I remember. | | | | |\n| 13 | Q Okay. And do you -- and do you recall | 13 | | A I don't remember. | |\n| 14 | that that | 14 | Q | | |\n| | | | | | |\n| | | | | | |\n| 17 | A I don't remember clearly. | 17 | | | |\n| 18 | Q | | | | |\n| | | | | | |\n| | | | | | |\n| | off the record.) | | | | |\n| | | | | | |\n| 22 | THE WITNESS: I don't remember. | 22 | | BY MR. LUFT: | |\n| 23 | MR. LUFT: Okay. Let's mark as | 23 | | Q That's okay. | |\n| 24 | Exhibit 16, | 24 | | | |\n| | | | | | |\n| | Page 90 | | | | Page 92 |\n| 1 | | 1 | | | |\n| | | 2 | | A I don't remember. | |\n| | | 3 | Q | | |\n| | | | | | |\n| | | | | | |\n| | | 6 | | A I have gone to view the house before. | |\n| | | | | | |\n| | were marked for I.D.) | 7 | | Q I appreciate -- that's helpful. | |\n| 8 | BY MR. LUFT: | 8 | | | |\n| 9 | Q Ms. Ngok, my first question is simple: | | | | |\n| 10 | | | | | |\n| | | | | | |\n| | | | | | |\n| 13 | A Where is the dates? | 13 | | A It was me. | |\n| 14 | Q | 14 | | Q Okay. And when did you make that | |\n| | | 15 | | decision? | |\n| | | 16 | | A I don't remember very clearly. | |\n| | | | | | |\n| 17 | MR. MAJOR: Objection to form. | 17 | | Q Okay. | |\n| 18 | BY MR. LUFT: | | | | |\n| 19 | Q | | | | |\n| | | | | | |\n| | | | | | |\n| | | | | | |\n| | | | | | |\n| | | | | | |\n| | | | | | |\n| | | 25 | | A I don't remember. | |\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 26 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 27 of 52\n\n| | Page 93 | | Page 95 | |\n|-----------|------------------------------------------------------|----|-------------------------------------------|--|\n| 1 | Q | 1 | | |\n| | | 2 | BY MR. LUFT: | |\n| | | 3 | Q Okay. And do you see -- | |\n| 4 | A I don't. | 4 | A | |\n| 5 | Q | 5 | Q Understood. | |\n| | | 6 | | |\n| | | | | |\n| | | | | |\n| 9 | A I do not remember. | | | |\n| 10 | Q Okay. I'm going to show you a document | 10 | MR. MAJOR: Objection to form. | |\n| 11 | that I'll ask the court reporter to mark as | 11 | THE WITNESS: Okay. | |\n| | | 12 | BY MR. LUFT: | |\n| 12 | Exhibit 18, which has a control number on it of | | | |\n| 13 | 00016119. That number is the number for the entire | 13 | Q | |\n| 14 | document. It was produced to us without Bates | | | |\n| 15 | stamps, so just for clarity, we put a control number | | | |\n| 16 | on it. | 16 | MR. MAJOR: Objection to form. | |\n| 17 | | 17 | THE WITNESS: I really do not remember. | |\n| | | 18 | BY MR. LUFT: | |\n| | | 19 | Q Okay. Let me show you another document. | |\n| | | 20 | MR. LUFT: Let's mark as Exhibit 19 -- | |\n| 21 | (Exh bit 18 was marked for I.D.) | 21 | COURT REPORTER: Sorry. | |\n| 22 | THE WITNESS: Okay. | 22 | MR. LUFT: Sorry. | |\n| 23 | BY MR. LUFT: | 23 | -- a document bearing the control stamp | |\n| 24 | Q Ms. Ngok, do you recognize this document? | 24 | CTRL00016119, which purports to be | |\n| 25 | MR. MAJOR: Objection to form. | | | |\n| | Page 94 | | Page 96 | |\n| 1 | THE WITNESS: I -- I'm sure I'm not able | 1 | | |\n| 2 | to recognize it. | | | |\n| 3 | BY MR. LUFT: | 3 | (Exhibit 19 was marked for I.D.) | |\n| 4 | Q Okay. Well, let's see if we can find | 4 | THE WITNESS: Okay. | |\n| 5 | something you recognize. | 5 | MR. MAJOR: Object | |\n| 6 | | 6 | BY MR. LUFT: | |\n| | | 7 | Q | |\n| | | | | |\n| | | | | |\n| | | | | |\n| | | | | |\n| 12 | A Can you point it out to me which page it | | | |\n| 13
is? | | | | |\n| 14 | Q Of course, ma'am. I can show you on mine. | | | |\n| 15 | I'm about eight pages in -- | | | |\n| | | | | |\n| 16 | MR. LUFT: | | | |\n| | | | | |\n| 18 | THE WITNESS: You mean this page | | | |\n| 19 | (indicating)? | | | |\n| 20 | BY MR. LUFT: | | | |\n| 21 | Q | | | |\n| | | 22 | INTERPRETER: Sorry. | |\n| | | 23 | BY MR. LUFT: | |\n| 24 | MR. MAJOR: Objection to form. | 24 | Q | |\n| 25 | THE WITNESS:
, | | | |\n| | | | | |\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 27 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 28 of 52\n\n| Page 97
1
3
A I don't remember.
4
Q Okay. You can put that aside.
5
A Okay.
6
Q Let me show you, then --
7
MR. LUFT: Let's mark as Exhibit 20 --
8
(A discussion was held off the
9
stenographic record.)
10
MR. LUFT: We'll mark as Exhibit 20 a
11
document with the control number CTRL00016119.
12
Again, this is a multipage document that was
13
produced to us without Bates stamps, so we just
14
put it on there.
15 | Page 99
1
THE WITNESS: No, it's not.
2
MR. LUFT: It's -- I don't want to say it,
3
'cause I assume you don't want her social
4
security number in the record so
5
MR. MAJOR:
7
MR. LUFT: Well
8
BY MR. LUFT:
9
Q
12
A You mean this one (indicating)?
13
Q Yes, ma'am.
14
A |\n|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| 19
(Exhibit 20 was marked for I.D.)
20
THE WITNESS: Okay.
21
BY MR. LUFT:
22
Q
Page 98
1
of you.
2
A Where did you see page No. 7?
3
Q | 23
MR. LUFT: Completely fair.
24
THE WITNESS: I do not -- I don't speak
25
English, I don't understand English, and I
Page 100
1
2
BY MR. LUFT:
3
Q |\n| 7
MR. MAJOR: Can I just flip to it for her?
8
MR. LUFT: I -- I did. She has it.
9
THE WITNESS: I am on it, but I don't know
10
if that's the correct one.
11
BY MR. LUFT:
12
Q That's the correct -- you're on the same
13
page as me.
14
19
A | don't remember. I really don't
11
remember.
12
Q Okay. |\n| 24
THE WITNESS: No, it is not either.
25
MR. LUFT: No, it's not -- it's | 25
A It's an apartment? It's an apartment? |\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 28 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 29 of 52\n\n| Page 101
Page 103
1 |\n|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| 3
MR. MAJOR: Objection to form.
4
THE WITNESS: Okay. I see it.
5
BY MR. LUFT:
6
Q |\n| 9
MR. MAJOR: Objection to form.
10
THE WITNESS: Yes.
11
BY MR. LUFT:
12
Q |\n| 19
MR. MAJOR: Objection to form.
20
THE WITNESS: I do not know.
21
BY MR. LUFT:
22
Q |\n| Page 102
Page 104
1
MR. MAJOR: Objection.
2
THE WITNESS: I don't know.
3
BY MR. LUFT:
reporter to mark as Exhibit 21 another document |\n| 12
BY MR. LUFT:
13
Q Does anyone at Greenwich Land know the |\n| 14
answer to that question?
15
MR. MAJOR: Objection to form.
16
THE WITNESS: Can you repeat?
17
MR. LUFT: Sure.
18
BY MR. LUFT: |\n| 19
Q Does anyone at Greenwich Land know the
20
answer to that question?
21
MR. MAJOR: Objection to form.
22
THE WITNESS: Me too don't know.
23
MR. LUFT: Okay. Ms. Ngok, I want to
24
be -- it's warm in here. How are you feeling?
25
And do you need a break? |\n| |\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 29 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 30 of 52\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 30 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 31 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 31 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 32 of 52\n\n| | Page 113 | Page 115 |\n|----|----------------------------------------------------|-----------------------------------------------------------|\n| 1 | Ms. Ngok, do you know what Bento | 1
THE WITNESS: I don't remember. |\n| 2 | Technologies is? | 2
BY MR. LUFT: |\n| 3 | A I do not know. | 3
Q |\n| 4 | Q Ms. Ngok, you previously told me you have | |\n| 5 | a debit card for Greenwich Land -- for a Greenwich | |\n| 6 | Land account? | |\n| 7 | A I don't know what it is. It's -- I call | |\n| 8 | it the \"consumer\" card. I can use it to consume | |\n| 9 | things, but I don't know what you call it. | |\n| 10 | Q Ms. Ngok, that card is issued by Bento | 10
MR. MAJOR: Objection to form. |\n| 11 | Technologies, correct? | 11
THE WITNESS: I don't remember clearly. |\n| 12 | MR. MAJOR: I've just been advised that | 12
BY MR. LUFT: |\n| 13 | there may have been a part missing from the | 13
Q Okay. |\n| 14 | translation. She said something about not | |\n| | | |\n| 15 | taking money out of the card. | |\n| 16 | (Ms. Song speaking Mandarin.) | |\n| 17 | (The reporter requested clarification.) | |\n| 18 | MS. SONG: So she just mentioned that she | 18
A I do not know. |\n| 19 | never tried to take money out using that Bento | 19
Q Okay. In the interest of trying to save |\n| 20 | card and that she just used it to make some | 20
some time, I'm going to ask you a question that |\n| 21 | consumptions. So the part of -- | 21
consolidates a number of these exhibits. But if you |\n| 22 | MR. LUFT: You can't take down her | 22
need me to break any of it up, please let me know. |\n| 23 | testimony. | |\n| 24 | INTERPRETER: Can the interpreter | |\n| 25 | reinterpret? | |\n| | Page 114 | Page 116 |\n| 1 | MR. LUFT: That's perfectly fine. | |\n| 2 | INTERPRETER: Yeah, that's the proper way | |\n| 3 | to do it. | |\n| 4 | (Interpreter speaking Mandarin.) | |\n| 5 | THE WITNESS: Okay. I don't know what it | |\n| 6 | is called. I call it the \"consumer\" card. I | |\n| 7 | can use it to consume -- buy things, but I | |\n| 8 | never withdrawal any cash out of it. But I | |\n| 9 | don't know what you call it. | |\n| 10 | MR. LUFT: Okay. Everyone good with that? | |\n| 11 | That's okay? Okay. | |\n| 12 | BY MR. LUFT: | |\n| 13 | Q Okay. | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| 24 | INTERPRETER: I'm sorry. | |\n| 25 | MR. MAJOR: Objection to form. | |\n| | | |\n| | | |\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 32 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 33 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 33 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 34 of 52\n\n| Page 121 | Page 123 |\n|----------------------------------------------------------|----------------------------------------------------------|\n| 1
the record; you don't have to do anything with them | 1 |\n| 2
right now. | |\n| 3
MR. LUFT: I marked a document bearing -- | |\n| 4
as Exhibit 34 bearing the Bates stamp | |\n| 5 | 5
Chris, do you want her to translate all |\n| | 6
that or? |\n| | 7
MR. MAJOR: I'm okay not translating all |\n| | 8
that. |\n| 9
As Exhibit 35, the next in that series, | 9
MR. LUFT: Okay. |\n| 10 | 10
THE WITNESS: Okay. I'll just give a gist |\n| | 11
of it. |\n| | 12
MR. LUFT: You can just tell her that I -- |\n| | 13
INTERPRETER: Oh, sorry. Just give me one |\n| 14
(A discussion was held off the | 14
second. |\n| 15
stenographic record.) | 15
(Interpreter speaking Mandarin.) |\n| 16
MR. LUFT: Exh bit -- we've marked as | 16
THE WITNESS: Okay. |\n| 17
Exhibit 36 another | 17
BY MR. LUFT: |\n| | 18
Q Ms. Ngok, I'll ask you to turn to -- if |\n| | 19
you could just pull out Exhibit 22 and Exhibit 33. |\n| | 20 |\n| | |\n| 22
We marked as Exhibit 37 a | |\n| | 23
INTERPRETER: Sorry. |\n| | 24
MR. LUFT: Go ahead. |\n| | 25
THE WITNESS: Yes. |\n| | |\n| Page 122 | Page 124 |\n| 1
Exhibit -- we marked as Exhibit 38 | 1
BY MR. LUFT: |\n| | 2
Q |\n| | |\n| | |\n| | |\n| 6
We marked as Exhibit 39 | |\n| | 7
MR. MAJOR: Objection to form. |\n| | 8
THE WITNESS: I see it. |\n| | 9
BY MR. LUFT: |\n| | 10
Q |\n| 11
We marked as Exhibit 40 | |\n| | |\n| | |\n| | |\n| | |\n| 16
And we marked as Exhibit 41 | 16
MR. MAJOR: Objection to form. |\n| | 17
THE WITNESS: Which date? |\n| | 18
MR. LUFT: |\n| | 19
THE WITNESS: Yes, I see it. |\n| 20
We marked as Exhibit 42 | 20
BY MR. LUFT: |\n| | 21
Q Okay. In the interest of trying to save |\n| | 22
time |\n| | |\n| | |\n| 25
And as Exhibit 43, | |\n| | |\n| | |\n\nCase 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 34 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 35 of 52\n\n| Page 125 | Page 127 |\n|----------------------------------------------------------|-----------------------------------------------------------|\n| 1 | 1
BY MR. LUFT: |\n| | 2
Q Ms. Ngok, who had the authority to write |\n| | 3
checks on behalf of Greenwich Land's bank account at |\n| | 4
The First Bank of Greenwich? |\n| | 5
MR. MAJOR: Objection to form. |\n| 6
INTERPRETER: Thank you. | 6
THE WITNESS: I do not know. |\n| 7
MR. LUFT: Thank you. | 7
BY MR. LUFT: |\n| 8
THE WITNESS: I understand. | 8
Q Who at -- who at Greenwich Land had to |\n| 9
BY MR. LUFT: | 9
authorize the writing of checks from Greenwich |\n| 10
Q | 10
Land's bank account at The First Bank of Greenwich? |\n| | 11
MR. MAJOR: Objection to form. |\n| | 12
THE WITNESS: I do not know. |\n| | 13
BY MR. LUFT: |\n| | 14
Q Ms. Ngok, are you familiar with a company |\n| | |\n| | 15
called Gypsy Mei -- M-E -- \"Mei\" is spelled M-E-I, |\n| 16
A Yes. | 16
same as your daughter's -- Food Service, LLC? |\n| 17
Q | 17
A I am not familiar with this. |\n| | 18
MR. LUFT: Okay. So let's mark as |\n| | 19
Exhibit 45 a document bearing the Bates stamp |\n| | 20
HR0003000 through 32, titled \"Minute Book of |\n| | 21
Gypsy Mei Food Services, Hodgson Russ, |\n| | 22
Attorneys.\" |\n| | 23
(Exhibit 45 was marked for I.D.) |\n| | 24
BY MR. LUFT: |\n| 25
MR. MAJOR: Objection to form. | |\n| Page 126 | Page 128 |\n| 1
THE WITNESS: I do not know. | |\n| 2
BY MR. LUFT: | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| 13
Q Okay. We're going to come back to these, | |\n| 14
but for now you can put them to the side for a | |\n| 15
second. | |\n| 16
(A discussion was held off the | |\n| 17
stenographic record.) | |\n| 18
BY MR. LUFT: | |\n| 19
Q Ms. Ngok, I'm going to ask the court | |\n| 20
reporter to mark as Exhibit 44 a document produced | |\n| 21
to us by | |\n| | |\n| The document bears the Bates stamp -- or | |\n| | |\n| 24
control number CTRL00016116. | 24
BY MR. LUFT: |\n| 25
(Exhibit 44 was marked for I.D.) | |\n| | |\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 35 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 36 of 52\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 36 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 37 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 37 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 38 of 52\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 38 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 39 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 39 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 40 of 52\n\n| | Page 145 | | Page 147 |\n|----|------------------------------------------------------|----|------------------------------------------------------|\n| 1 | MR. MAJOR: That's fine. | 1 | Max Krasner resigned from his position at Greenwich |\n| 2 | BY MR. LUFT: | 2 | Land. Are you aware of those statements to the |\n| 3 | Q Okay. And specifically, Interrogatory | 3 | court? |\n| 4 | No. 6 asks Greenwich Land to \"Identify all employees | 4 | A I do not know. |\n| 5 | of Greenwich Land, including directors and officers, | 5 | MR. MAJOR: Just objection. I just want |\n| 6 | and the role of each identified individual.\" | 6 | to -- it's fine, the answer is out. But just |\n| 7 | And in response Greenwich Land stated that | 7 | because it dealt with the court, I was going to |\n| 8 | you are presently the sole member of Greenwich Land | 8 | put in an objection regarding privilege. But |\n| 9 | and Greenwich Land presently has no separate | 9 | she's already answered it and it didn't reveal |\n| 10 | manager, officers, or employees. And then it says | 10 | any privileged communication. So I pardon the |\n| 11 | Greenwich Land previously had officers. Yvette | 11 | interruption, but I just wanted to note that |\n| 12 | Wang, Daniel Podhaskie, and Max Krasner previously | 12 | since I had already interrupted, just telling |\n| 13 | served in the roles of vice president of Greenwich | 13 | you why. |\n| 14 | Land. All of them resigned before the end of 2022? | 14 | (A discussion was held off the |\n| 15 | INTERPRETER: End of 2022? | 15 | stenographic record.) |\n| 16 | MR. LUFT: Yes, that's what it says. | 16 | THE WITNESS: Okay. |\n| 17 | BY MR. LUFT: | 17 | BY MR. LUFT: |\n| 18 | Q Ms. Ngok, was that information correct | 18 | Q Ms. Ngok, if it helps refresh your |\n| 19 | when you signed and verified these interrogatories? | 19 | recollection, if you look at page 6 of your |\n| 20 | MR. MAJOR: Objection to form. | 20 | interrogatories, under \"Right to Supplement,\" it |\n| 21 | THE WITNESS: Yes. | 21 | references language related to Max Krasner resigning |\n| 22 | BY MR. LUFT: | 22 | on November 5, 2022. Does that refresh your |\n| 23 | Q Okay. So is it fair to say that, to | 23 | recollection that someone by the name of Max Krasner |\n| 24 | Greenwich Land's knowledge, Chunguang Han was never | 24 | resigned from Greenwich Land on November 5, 2022? |\n| 25 | a manager, officer, or employee of Greenwich Land? | 25 | MR. MAJOR: Objection to form. |\n| | | | |\n| 1 | Page 146
MR. MAJOR: Objection to form. | 1 | Page 148
(A discussion was held off the |\n| 2 | THE WITNESS: I've never heard about it. | 2 | stenographic record.) |\n| 3 | BY MR. LUFT: | 3 | THE WITNESS: Which page? |\n| 4 | Q Okay. Is it also fair to say that your | 4 | BY MR. LUFT: |\n| 5 | daughter, Mei Guo, has also never been a manager, | 5 | Q Page 6. |\n| 6 | director, or officer of Greenwich Land -- or | 6 | A I can't read it. |\n| 7 | employee. | 7 | Q That's okay. |\n| 8 | MR. LUFT: Sorry. | | |\n| 9 | INTERPRETER: Sorry. | | |\n| 10 | THE WITNESS: How do I put it? Well, I | | |\n| 11 | don't know. | | |\n| 12 | BY MR. LUFT: | | |\n| 13 | Q Okay. Well, when you signed the | | |\n| 14 | interrogatory -- certified -- signed the | | |\n| 15 | interrogatories to certify the answer, did Greenwich | | |\n| 16 | Land have any reason to believe that Mei Guo has | | |\n| 17 | been an employee, director, or officer of Greenwich | | |\n| 18 | Land, such that she should be included in the | | |\n| 19 | answer? | | |\n| 20 | MR. MAJOR: Objection to form. | | |\n| 21 | THE WITNESS: I'm not sure about that. | 21 | BY MR. LUFT: |\n| 22 | BY MR. LUFT: | 22 | Q Okay. Do you see if, when we look at the |\n| 23 | Q Okay. And, Ms. Ngok, Greenwich Land has | 23 | exhibits -- |\n| 24 | filed documents with the court in this case stating | 24 | INTERPRETER: Okay. The interpreter would |\n| 25 | that on November 5, 2022, a person by the name of | 25 | like to rectify the answer. The answer is \"I'm |\n| | | | |\n\n\n\nCase 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 40 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 41 of 52\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 41 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 42 of 52\n\n| Page 153 | Page 155 |\n|-------------------------------------------------|-------------------------------------------------------------|\n| 1 | |\n| | |\n| | |\n| 4
(Exhibit 47 was marked for I.D.) | |\n| 5
MR. LUFT: I'm going to ask the court | |\n| 6
reporter to mark as Exhibit 48 | 6
MR. MAJOR: Objection to form. |\n| | 7
THE WITNESS: |\n| | |\n| | |\n| 10
(Exhibit 48 was marked for I.D.) | |\n| 11
MR. LUFT: I'm going to ask the court | |\n| 12
reporter to mark as Exhibit 49 | 12
BY MR. LUFT: |\n| | 13 |\n| | |\n| | |\n| 16
(Exhibit 49 was marked for I.D.) | 16
MR. MAJOR: Objection to form. |\n| 17
MR. LUFT: And I'll ask the court reporter | 17
THE WITNESS: |\n| 18
to mark Exhibit 50 | |\n| | |\n| | 21
BY MR. LUFT: |\n| 22
(Exhibit 50 was marked for I.D.) | 22
Q Okay. Well, Ms. Ngok, let's just go to |\n| 23
MR. LUFT: | 23
our most recent one, which is from -- well, let me |\n| | 24
strike that. Let me find one that may stick out a |\n| | 25
bit more. |\n| | |\n| Page 154
1 | Page 156
1
And -- well, let me first -- let me strike |\n| | 2
that. |\n| | 3
(The following testimony was deemed highly |\n| | 4
confidential.) |\n| | 5
BY MR. LUFT: |\n| 6
MR. MAJOR: Objection to form. | 6
Q |\n| 7
THE WITNESS: I'm not able to read this | |\n| 8
document. | |\n| 9
BY MR. LUFT: | |\n| 10
Q | 10
(The reporter requested clarification.) |\n| | 11
BY MR. LUFT: |\n| | |\n| | |\n| 14
INTERPRETER: Can I have the question | |\n| 15
again, sir? | |\n| 16
MR. LUFT: You could just strike it. | |\n| 17
BY MR. LUFT: | |\n| 18
Q | |\n| | 19
MR. MAJOR: Hold on. Hold on. I don't |\n| | 20
want to have any attorney-client privileged |\n| 21
A Yes. | 21
communications put on the record. So I just |\n| 22
Q | 22
want to -- I don't know what the best thing to |\n| | 23
do is, but I'd like to maybe -- and I have no |\n| | 24
idea what the rest of the answer was, so I |\n| | 25
don't know if it just a passing reference or |\n| | |\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 42 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 43 of 52\n\n\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 43 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 44 of 52\n\n| | Page 161 | Page 163 |\n|---------------------------------|----------|---------------------------------------------------|\n| BY MR. LUFT: | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | 24 | BY MR. LUFT: |\n| | 25 | Q Ms. Ngok, are you familiar with the |\n| | | |\n| | Page 162 | Page 164 |\n| 1
THE WITNESS: I don't know. | 1 | restaurant Henry Cipriani, which is in the same |\n| BY MR. LUFT: | 2 | building as the Sherry Netherland apartment? |\n| | 3 | A I am not familiar. |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | 13 | BY MR. LUFT: |\n| | 14 | Q Ms. Ngok, have you personally ever eaten |\n| | 15 | at Henry Cipriani [sic], which is located in the |\n| | 16 | same building as the Sherry Netherland hotel? |\n| | 17 | A Yes, I have dined in the same -- in that |\n| | | |\n| | 18 | restaurant before, but that was years back when I |\n| | 19 | first came to the United States, probably in the |\n| | 20 | year of 2017. |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n| | | |\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 44 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 45 of 52\n\n| Page 165 | Page 167 |\n|---------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------|\n| 1
THE WITNESS: I only have breakfast in the
2
restaurant when I first came to the United | |\n| 3
States back in 2017. | |\n| | |\n| | |\n| 6
BY MR. LUFT:
7
Q But he is a person who has signed -- | |\n| 8
opened bank accounts and signed documents on behalf | |\n| 9
of Greenwich Land, correct? | |\n| 10
MR. MAJOR: Just objection to form. | |\n| 11
I'm sorry.
12
THE WITNESS: I don't know about that. | |\n| 13
BY MR. LUFT: | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | 21
(Exhibit 51 was marked for I.D.)
22
BY MR. LUFT: |\n| | 23
Q |\n| | |\n| | |\n| Page 166 | Page 168 |\n| | 1
A I don't remember.
2
Q Okay. Let me show you -- let's mark as |\n| | 3
Exhibit 52 a |\n| | |\n| | |\n| | 7
(Exhibit 52 was marked for I.D.) |\n| | 8
BY MR. LUFT: |\n| | 9
Q |\n| | |\n| | form.
12
THE WITNESS: |\n| | |\n| | 14
BY MR. LUFT: |\n| | 15
Q |\n| | |\n| | |\n| | |\n| | |\n| | 21
MR. MAJOR: Objection to form.
22
THE WITNESS: I don't remember. |\n| | 23
MR. LUFT: Okay. Let's mark as -- |\n| | 24
MR. MAJOR: Can I just ask a question on |\n| | 25
Exhibit 52? |\n| | |\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 45 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 46 of 52\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 46 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 47 of 52\n\n| Page 173 | Page 175 |\n|------------------------------------------------|----------------------------------------------------------------------------------------------------------------------|\n| 1
BY MR. LUFT: | 1
later? |\n| 2
Q What if -- please tell me -- | 2
MR. MAJOR: Objection to form. |\n| 3
A I do not know who. | 3
THE WITNESS: I do not know. |\n| 4
INTERPRETER: Sorry. | 4
BY MR. LUFT: |\n| 5
MR. LUFT: Okay. | 5
Q |\n| 6
BY MR. LUFT: | |\n| | |\n| | 8
A I do not know. |\n| | 9
Q Ms. Ngok, are you familiar with someone by |\n| 10
MR. LUFT: Okay. Let's mark as Exhibit 55 | 10
the name of Dinggang Wang? |\n| 11
a | 11
INTERPRETER: Can I have the spelling of
12
the name, sir? |\n| | 13
MR. LUFT: D-I-N-G-G-A-N-G, space, Wang, |\n| 14
(Exhibit 55 was marked for I.D.) | 14
W-A-N-G. |\n| 15
BY MR. LUFT: | 15
THE WITNESS: I am not familiar. |\n| | 16
BY MR. LUFT: |\n| | 17
Q |\n| | |\n| | 19
A I do not know. |\n| | 20
Q Okay. Ms. Ngok, I'm going to have marked |\n| | 21
as Exhibit -- what are we up to, 56? -- 56 documents |\n| | 22
entitled \"Residential Lease Renewal Agreement,\" |\n| | 23
between Greenwich Land, LLC, and Wang Dinggang. |\n| | 24
(Exhibit 56 was marked for I.D.) |\n| 25
A I don't know. I don't know why. | 25 |\n| Page 174 | Page 176 |\n| 1
(A discussion was held off the record.) | 1
BY MR. LUFT: |\n| 2
BY MR. LUFT:
3
Q | 2
Q Ms. Ngok, do you recognize this document?
3
A I don't remember. |\n| | 4
Q Did you ever authorize Greenwich Land to |\n| | 5
lease 33 Ferncliff to a man named Dinggang Wang? |\n| | 6
A I don't remember. |\n| | 7
Q Ms. Ngok, I'm going have the court |\n| | 8
reporter mark as Exhibit 57 a copy of a document |\n| | 9
entitled \"Residential Lease Renewal Waiver |\n| 10
MR. MAJOR: Objection to form. | 10
Agreement,\" which is an agreement between, again, |\n| 11
THE WITNESS: I really do not know why. | 11
Greenwich Land, LLC, and Mr. Wang Dinggang dated |\n| 12
BY MR. LUFT: | 12
October 9, 2020. |\n| 13
Q | 13
(Exhibit 57 was marked for I.D.) |\n| | 14
BY MR. LUFT: |\n| | 15
Q Ms. Ngok, who authorized Greenwich Land to |\n| | 16
enter into this agreement with Mr. Dinggang Wang
17
related to he and his family living at 33 Ferncliff? |\n| 18
MR. MAJOR: Objection. | 18
MR. MAJOR: Objection to form. |\n| 19
THE WITNESS: I do not understand your | 19
THE WITNESS: I'm not sure. |\n| 20
question. | 20
BY MR. LUFT: |\n| 21
BY MR. LUFT: | 21
Q Okay. Ms. Ngok, is part of Greenwich |\n| 22
Q | 22
Land's business to do media consulting? |\n| | 23
A I'm not sure. |\n| | 24
Q You're the sole member of Greenwich Land. |\n| | 25
Are you aware of any media business that Greenwich |\n| | |\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 47 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 48 of 52\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 48 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 49 of 52\n\n| | Page 181 | 1 | Page 183
INTERPRETER: Can the interpreter clarify? |\n|----|------------------------------------------------------|----|-------------------------------------------------------|\n| | | 2 | I was still interpreting the first question; |\n| 3 | MR. LUFT: Let's mark as Exhibit 59 a | 3 | you asked a second question. Can the |\n| 4 | document titled \"Retail Fuel Delivery and | | |\n| | | 4 | interpreter reinterpret? |\n| 5 | Service Agreement,\" dated February 6, 2020, | 5 | MR. LUFT: And then she answered the |\n| 6 | under the name of Ho Wan Kwok for the address | 6 | question, correct? |\n| 7 | of 30 Ferncliff Road [sic]. | 7 | INTERPRETER: Yes, she answered the |\n| 8 | (Exhibit 59 was marked for I.D.) | 8 | question. She said yes. |\n| 9 | (A discussion was held off the | 9 | MR. LUFT: To my first question, and |\n| 10 | stenographic record.) | 10 | then -- |\n| 11 | MR. LUFT: Guys, I have to ask for a copy | 11 | MR. MAJOR: I don't know -- I disagree |\n| 12 | back. Sorry. Thank you. | 12 | with that. |\n| 13 | BY MR. LUFT: | 13 | MR. LUFT: You can't disagree. She's the |\n| 14 | Q Ms. Ngok, this is a fuel delivery | 14 | interpreter, Chris. She's telling you that's |\n| 15 | agreement -- | 15 | what happened. |\n| 16 | MR. MAJOR: Wait. Hold on. The -- you | 16 | MR. MAJOR: I'm talking about the order of |\n| 17 | just took our copies back and -- | 17 | the questions. |\n| 18 | MR. LUFT: I didn't take your copies. You | 18 | MR. LUFT: Do you speak Chinese? |\n| 19 | have two lawyers; I gave you one. You guys | 19 | MR. MAJOR: First of all, that's not a |\n| 20 | still have one, right? | 20 | language but -- and you've been saying that all |\n| 21 | MR. MAJOR: No, we gave them both back. | 21 | day but |\n| 22 | You said it was the wrong document. | 22 | MR. LUFT: It's not? No, there are two |\n| 23 | MR. LUFT: No, I just needed a copy. | 23 | dialects I think you're referring to, but |\n| 24 | MR. MAJOR: Ah, okay. | 24 | there's obviously a language of Chinese, and |\n| 25 | | 25 | Mandarin is commonly referred to as \"Chinese.\" |\n| | | | |\n| | | | |\n| | Page 182 | | Page 184 |\n| 1 | BY MR. LUFT: | 1 | Let's not waste time. |\n| 2 | Q Ms. Ngok, this is a retail fuel delivery | 2 | MR. MAJOR: Hold on. |\n| 3 | and service agreement dated February 6, 2020, for | 3 | MR. LUFT: Chris, I understand there's ten |\n| 4 | the address 33 Ferncliff Road, Cos Cob, Connecticut, | 4 | minutes; I understand you're trying to run it |\n| 5 | under the name of Ho Wan Kwok. | 5 | out all of a sudden with all these -- |\n| 6 | MR. MAJOR: Objection to form. | 6 | MR. MAJOR: I'm not trying to run it out. |\n| 7 | BY MR. LUFT: | 7 | You asked a compound question; I'm objecting to |\n| 8 | Q 33 Ferncliff Road is the house Greenwich | 8 | the compound question. |\n| 9 | Land owned, correct? And Ho Wan Kwok is the name of | 9 | MR. LUFT: Okay. |\n| 10 | your husband, correct? | 10 | Ms. Interpreter, can you please explain |\n| 11 | MR. LUFT: She just answered something, | 11 | what happened? |\n| 12 | echo. You got to translate it. | 12 | (The reporter requested clarification.) |\n| 13 | MR. MAJOR: Hold on. I have -- it's a | 13 | INTERPRETER: Can -- the interpreter was |\n| 14 | compound question. You asked her what the | 14 | still interpreting the first question and |\n| 15 | document was -- | 15 | Ms. -- Ms. Guo actually answered the second |\n| 16 | MR. LUFT: She answered and it wasn't | 16 | question while I was interpreting them. |\n| 17 | translated, Chris. | 17 | Can the interpreter reinterpret both the |\n| 18 | MR. MAJOR: No, but you asked two | 18 | questions? |\n| 19 | questions at once. | 19 | MR. LUFT: Why don't I just withdraw it |\n| 20 | MR. LUFT: No, Chris, it just wasn't | 20 | and we'll just do it very quick? |\n| 21 | translated. She answered. | 21 | INTERPRETER: Okay, then. |\n| 22 | MR. MAJOR: I'm looking at the realtime, | 22 | BY MR. LUFT: |\n| 23 | and I heard you -- | 23 | Q Exhibit 59 says 33 Ferncliff Road, which |\n| 24 | MR. LUFT: Whatever the -- 'cause Echo | 24 | is a house you had previously told me was owned by |\n| 25 | didn't translate it, Chris. | 25 | Greenwich Land, the name on the account of -- is Ho |\n\n\n\n# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 49 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 50 of 52\n\n| | Page 185 | | Page 187 |\n|----|------------------------------------------------------|----|------------------------------------------------|\n| 1 | Wan Kwok. That is your husband, correct? | 1 | BY MR. LUFT: |\n| 2 | MR. MAJOR: Objection to form, including | | |\n| 3 | compound. | | |\n| 4 | THE WITNESS: I never said that the | | |\n| 5 | 33 Ferncliff Road house is under my husband's | | |\n| 6 | name. | | |\n| 7 | BY MR. LUFT: | 7 | BY MR. LUFT: |\n| 8 | Q No, I understand that. The document -- | | |\n| 9 | but Exhibit 59, which is the fuel agreement, states | | |\n| 10 | that 33 Ferncliff Road is under your husband's name, | | |\n| 11 | correct? | | |\n| 12 | MR. MAJOR: Objection to form. | | |\n| 13 | THE WITNESS: I still do not know what | | |\n| 14 | this document means, even right now. | | |\n| 15 | BY MR. LUFT: | | |\n| 16 | Q Ms. Ngok, do you have any involvement with | | |\n| | | | |\n| 17 | paying the fuel bill for -- did you have any | 17 | MR. LUFT: Ms. Ngok, I have no further |\n| 18 | involvement with paying the fuel bill for | 18 | questions at this time. Thank you very much |\n| 19 | 33 Ferncliff Road? | 19 | for what has been long and a very hot day in |\n| 20 | A You mean fuel? What is it? | 20 | this room. |\n| 21 | Q Yes. | 21 | THE WITNESS: Thank you, everybody. It |\n| 22 | A It's like gasoline? | 22 | has been a hard day for everyone. Thank you so |\n| 23 | Q The fuel that heats the home. | 23 | much. |\n| 24 | A And then? Then what? | 24 | MR. MAJOR: Actually, I just want to put |\n| 25 | Q My question is did you have any | 25 | two -- I'll be very, very quick. I'd like to |\n| | Page 186 | | Page 188 |\n| 1 | involvement in paying for the fuel bill for | 1 | mark the video and then the still images |\n| 2 | 33 Ferncliff Road? | 2 | thereof highly confidential for security |\n| 3 | A I don't remember. | 3 | reasons. |\n| 4 | Q Let me show you another document. | 4 | I'd like to reserve the right, as |\n| 5 | MR. LUFT: We're going to mark as | 5 | ridiculous as it may sound, to read and sign. |\n| 6 | Exhibit 60 a copy of a Petro Home Services bill | 6 | I just don't want to let that go. I know it's |\n| 7 | to Ho Wan Kwok at 33 Ferncliff Road, Cos Cob, | 7 | a logistical situation and we may well not do |\n| 8 | Connecticut. | 8 | that, but I just want to reserve that right. |\n| 9 | (Exhibit 60 was marked for I.D.) | 9 | MR. LUFT: Okay. |\n| 10 | BY MR. LUFT: | 10 | COURT REPORTER: And can I just get the |\n| 11 | Q Ms. Ngok, do you see that this a copy of a | 11 | orders on the record? |\n| 12 | fuel bill for 33 Ferncliff Road in the name of your | 12 | MR. LUFT: Sure. We'd like the rough and |\n| 13 | husband, Ho Wan Kwok? | 13 | expedited. |\n| 14 | MR. MAJOR: Objection to form. | 14 | MR. MAJOR: And I just ask that the |\n| 15 | THE WITNESS: I see his name, yes, but I | 15 | transcript be marked \"Confidential\" except |\n| 16 | don't recognize any other information on this | 16 | where we marked it \"Highly confidential,\" and |\n| 17 | page. | 17 | then we'll give it a review. And if there are |\n| 18 | MR. LUFT: Let's go off the record for a | 18 | spots that don't need to be marked, we'll deal |\n| 19 | minute. | 19 | with that then. |\n| 20 | VIDEOGRAPHER: We're off the record. The | 20 | MR. LUFT: I will -- I don't agree that |\n| 21 | time is 8:53. | 21 | everything on the record should be |\n| 22 | (A recess was taken.) | 22 | confidential. And that's going to create a |\n| 23 | VIDEOGRAPHER: We're back on the record. | 23 | major headache for the court when they have to |\n| 24 | The time is 9:01. | 24 | use this, including the fact that we all have |\n| 25 | | 25 | to make any use of it and any filings, both in |\n| | | | |\n| | | | |\n\n\n\n## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 50 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 51 of 52\n\n| | Page 189 | | Page 191 |\n|----|-----------------------------------------------|--------|---------------------------------------------------------------|\n| 1 | court and in briefs, confidential. I don't | 1 | C E R T I F I C A T E |\n| 2 | think there's any basis, other than where we | 2 | I hereby certify that I am a Notary Public, |\n| 3 | have specified that things should be marked | 3 | in and for the State of Connecticut, duly |\n| 4 | \"Confidential\" or \"Highly confidentially,\" to | 4 | commissioned and qualified to administer oaths. |\n| 5 | say that the rest of the record needs to be | 5 | I further certify that the deponent named in |\n| 6 | marked \"Confidential\" for the entire | 6 | the foregoing deposition was by me duly sworn, and |\n| 7 | deposition. | 7 | thereupon testified as appears in the foregoing |\n| 8 | MR. MAJOR: I was just saying it for a | 8 | deposition; that said deposition was taken by me |\n| 9 | period of time, to allow us to review the | 9 | stenographically in the presence of counsel and |\n| | | 10 | reduced to typewriting under my direction, and the |\n| 10 | transcript to see if there's anything we want | 11 | foregoing is a true and accurate transcript of the |\n| 11 | to mark \"Confidential.\" We can deal with that | 12 | testimony. |\n| 12 | off the record. | 13 | I further certify that I am neither of |\n| 13 | And then, in terms of the order, I'll take | 14 | counsel nor attorney to either of the parties to |\n| 14 | a -- I think regular delivery will be fine. | 15 | said suit, nor am I an employee of either party to |\n| 15 | And I'm sure it includes it, but a mini as | 16 | said suit, nor of either counsel in said suit, nor |\n| 16 | well. | 17 | am I interested in the outcome of said cause. |\n| 17 | COURT REPORTER: And did you want a rough? | 18 | Witness my hand and seal as Notary Public |\n| 18 | Sorry. | 19 | this 13th day of September, 2023. |\n| 19 | MR. MAJOR: I don't think we need a rough, | 20 | |\n| 20 | but if we do, we'll reach out to you. Is that | 21 | _______________________________ |\n| 21 | okay? | | Deborah Gentile |\n| 22 | COURT REPORTER: Sure. | 22 | Notary Public |\n| 23 | THE WITNESS: Thank you. | 23 | |\n| 24 | MR. LUFT: Thank you, everyone. | 24 | My commission expires:
October 31, 2026 |\n| 25 | MS. SONG: Thank you. | 25 | |\n| | Page 190 | | Page 192 |\n| 1 | VIDEOGRAPHER: This is concludes today's | 1 | |\n| 2 | deposition. We're off the record at 9:05 p.m. | 2 | INDEX OF EXAMINATIONS |\n| 3 | (The deposition concluded at 9:05 p.m.) | 3
4 | PAGE
DIRECT EXAMINATION BY MR. LUFT
7 |\n| 4 | | 5 | |\n| 5 | | 6
7 | INDEX OF EXHIBITS
TRUSTEE'S EXHIBITS MARKED FOR I.D. |\n| 6 | | 8 | Exhibit 1
- Notice of Deposition, Ms. Ngok
7 |\n| 7 | | 9 | Exhibit 2 - Notice of Deposition, Greenwich
8
Land, LLC |\n| 8 | | 10 | |\n| 9 | | | Exhibit 3 - Greenwich Land's Supplemental
21 |\n| 10 | | 11 | Responses to Interrogatories,
9/9/23 |\n| 11 | | 12 | |\n| 12 | | | Exhibit 4 - |\n| 13 | | 14 | Exhibit 5 - |\n| 14 | | | |\n| 15 | | 15 | Exhibit 6 - |\n| 16 | | | |\n| 17 | | 17 | Exhibit 7 - |\n| 18 | | 18 | |\n| 19 | | | Exhibit 8 - |\n| 20 | | 20 | Exhibit 9 - |\n| | | | |\n| 21 | | 21 | Exhibit 10 - |\n| 22 | | | |\n| 23 | | 23 | Exhibit 11 - |\n| 24 | | 24 | |\n| 25 | | 25 | |\n| | | | |\n\n#### Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 51 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 52 of 52\n\n| Page 193 | Page 195 |\n|----------------------------------------------|---------------------------------------------------------------------------------|\n| 1
2
INDEX OF EXHIBITS (CONT'D) | 1
2
INDEX OF EXHIBITS (CONT'D) |\n| 3
TRUSTEE'S EXHIBITS MARKED FOR I.D.
4 | 3
TRUSTEE'S EXHIBITS MARKED FOR I.D.
4 |\n| Exhibit 12 - | Exhibit 35 - |\n| 6
Exhibit 13 - | Exhibit 36 -
6 |\n| 7
Exhibit 14 - | 1
Exhibit 37 |\n| Exhibit 15
ਰੇ | Exhibit 38
ਰੇ |\n| 10 | 10 |\n| Exhibit 16 | Exhibit 39 |\n| Exhibit 17 -
12 | Exhibit 40
12 |\n| 13 | 13
Exhibit 41 - |\n| Exhibit 18 - | 15
Exhibit 42 |\n| 15
Exhibit 19 | 16 |\n| 16
Exhibit 20 | Exhibit 43 - |\n| Exhibit 21 -
18 | Exhibit 44 -
18
19 |\n| 19 | Exhibit 45 - \"Minute Book of Gypsy Mei Food
127
20
Services \" |\n| Exhibit 22 - | 21
Exhibit 46 - TRO and Preliminary Injunction,
152
3/28/23 |\n| 21
Exhibit 23 - | 22
Exhibit 47 - |\n| 22
23 | Exhibit 48 -
24 |\n| 24
25 | 25 |\n| Page 194 | Page 196 |\n| 1
2
INDEX OF EXHIBITS (CONT'D) | 1
2
INDEX OF EXHIBITS (CONT'D) |\n| 3
TRUSTEE'S EXHIBITS MARKED FOR I.D.
4 | 3
TRUSTEE'S EXHIBITS MARKED FOR I.D.
4 |\n| Exhibit 24 - | Exhibit 49 |\n| Exhibit 25 -
6 | Exhibit 50
6 |\n| 7
Exhibit 26 -
8 | 7
Exhibit 51 - |\n| | Exhibit 52
ರಿ |\n| 2
Exhibit 27 -
10 | 10 |\n| | Exhibit 53 - |\n| Exhibit 28
12 | 12
Exhibit 54 |\n| Exhibit 29 -
। ব | 13 |\n| | Exhibit 55 - |\n| | 175
15
Exhibit 56 - Residential Lease Renewal
Agreement, Mr. Wang |\n| Exhibit 31
18 | 16
Exhibit 57 - Residential Lease Renewal Waiver
176 |\n| | Agreement, Mr. Wang, 10/9/20
17
18
Exhibit 58 |\n| 20
Exhibit 32 - | 19 |\n| 21 | Exhibit 59 - Retail Fuel Delivery and Service
181
20
Agreement, 2/6/20 |\n| Exhibit 33 - | Exhibit 60 - Petro Home Services Bill, 33
21
186
Ferncliff Road |\n| 23
Exhibit 34 | 22
(Reporter's note: Exhibits attached to original.)
23 |\n| 24
25 | 24
25 |\n| A FOOTTIDE | |","body_zh":null,"key_entities":["Je","Guo","Kwok","Ho Wan Kwok","Despins","Saraca","Luc Despins","Paul Hastings"],"ecf_references":[{"doc_number":85,"court":"CTB"}],"word_count":18310,"status":"published","published_at":"2023-10-26 00:00:00","created_at":"2023-10-26","updated_at":"2026-07-07 08:02:11"}