{"id":"court_ctb_404_7","court":"CTB","case_no":"22-50073","doc_number":404,"sub_number":7,"doc_type":"EXHIBIT","filed_date":"2022-05-20","title":"EXHIBIT PAX 07 Transcript of the 341 Meeting of Creditors (Part I)","summary_zh":null,"summary_en":null,"body_en":"## **EXHIBIT PAX 07**\n\nTranscript of the 341 Meeting of Creditors (Part I)\n\nUNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT In Re \\* Chapter 11 \\* \\* HO WAN KWOK, \\* Case 22-50073(JAM) \\* Debtor. \\* \\* \\* \\* \\* \\* \\* \\* \\* \\* \\* \\* \\* \\* \\* \\* \\* \\* TRANSCRIPT OF TELEPHONIC 341 MEETING OF CREDITORS MARCH 21, 2022 Electronically Recorded by the Office of the United States Trustee Transcript Prepared By: Christine Fiore, CERT Fiore Reporting and Transcription Service, Inc. 4 Research Drive, Suite 402 Shelton, CT 06484 (203)929-9992\n\nHo Wan Kwok - March 21, 2022\n\n| APPEARANCES: | |\n|-----------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| For the Debtor: | WILLIAM R. BALDIGA, ESQ.
BEN SILVERBERG, ESQ.
URI PINELO, ESQ.
Brown Rudnick, LLP
Seven Times Square
New York, NY
10036 |\n| For the U.S. Trustee: | HOLLEY E. CLAIBORN, ESQ.
Office of the U.S. Trustee
150 State Street
New Haven, CT
06510 |\n| For Logan Cheng,
Creditor: | JAY MARSHALL WOLMAN, ESQ.
Randazza Legal Group
100 Pearl Street, 14th Floor
Hartford, CT 06103 |\n| For Pacific Alliance
Asia Opportunity Fund,
LP, Creditors: | DAVID V. HARBACH, II, ESQ.
O'Melveny & Myers, LLP
1625 I Street NW
Washington, DC
20006 |\n| | STUART SARNOFF, ESQ.
LAURA ARONSSON, ESQ.
CRAIG McALLISTER, ESQ.
MAKENZIE RUSSO
STEVEN WARREN
O'Melveny & Myers, LLP
Times Square Tower
7 Times Square
New York, NY
10036 |\n| For Bruno Wu, Weican
Meng and Rui Ma,
Creditors: | KAREN WARSHAUER
McElroy, Deutsch, Mulvaney &
Carpenter
One State Street
Hartford, CT
06103 |\n| For Xiaodan Wang,
Rong Zhang and Chong
Shen Raphanella,
Creditors: | LILLIAN GRINNELL, ESQ.
Wolf Haldenstein Adler
Freeman & Herz
270 Madison Avenue
New York, NY
10016 |\n\n2\n\nHo Wan Kwok - March 21, 2022\n\nAPPEARANCES: (Cont'd) For Samuel Nunberg, AMY ZAMIR, ESQ. Creditor: Nesenoff & Miltenberg, LLP 363 Seventh Avenue New York, NY 10001 For the Sherry EMILY KUZNICK, ESQ. Netherland, Creditor: Stroock, Stroock and Lavan 180 Maiden Lane New York, NY 10038\n\nHo Wan Kwok - March 21, 2022\n\n4\n\n| 1 | MS. CLAIBORN:
I'm going to repeat myself |\n|----|------------------------------------------------------|\n| 2 | from the beginning here because I want to make sure |\n| 3 | it's all on the record and I apologize. |\n| 4 | I'm going to basically start this meeting |\n| 5 | over again and we're going to go very quickly and |\n| 6 | then we'll come back to where I was just about to |\n| 7 | go. |\n| 8 | Today is Monday, March 21st, 2022 and we |\n| 9 | are gathered for the Section 341 meeting in the |\n| 10 | Chapter 11 case of Ho Wan Kwok, also known as Wengui |\n| 11 | Gwo and Miles Kwok. |\n| 12 | My name is Holley Claiborn and I'm a trial |\n| 13 | attorney in the Office of the United States Trustee |\n| 14 | and I will be conducting today's meeting. |\n| 15 | I am recording this meeting and also we |\n| 16 | have the presence of an interpreter on the line |\n| 17 | whose name is Bin, B-I-N. |\n| 18 | And so that I have it on the record, I'm |\n| 19 | going to ask Bin a third time about her oath. |\n| 20 | (The interpreter is sworn.) |\n| 21 | For purposes of speeding this up on the |\n| 22 | record we have appearances today by Jay Wolman, on |\n| 23 | behalf of Logan Cheng.
We have the appearance of |\n| 24 | David Harbach, Stuart Sarnoff, Mia Gonzalez, Laura |\n\nHo Wan Kwok - March 21, 2022\n\n5\n\n| 1 | Aronsson, Craig McAllister and Mackenzie Russo, all |\n|----|------------------------------------------------------|\n| 2 | on behalf of Pacific Alliance.
And for creditors |\n| 3 | Rui Ma, Bruno Wu and Weican Meng, we have Karen |\n| 4 | Warshauer, a paralegal at McElroy. |\n| 5 | THE INTERPRETER:
Sorry, I cannot get all |\n| 6 | those names at once. |\n| 7 | MS. CLAIBORN:
Bin, did you translate all |\n| 8 | of the names for the Pacific Alliance? |\n| 9 | THE INTERPRETER:
The names actually just |\n| 10 | a repeat of the pronunciation.
No translation. |\n| 11 | MS. CLAIBORN:
Thank you.
Whoever does |\n| 12 | not have their phone on mute, could you please put |\n| 13 | it on mute?
Thank you. |\n| 14 | Okay.
The other appearances, Karen |\n| 15 | Warshauer, from McElroy, and she represents Bruno |\n| 16 | Wu, Weican Meng and Rui Ma. |\n| 17 | Before I go back to the debtor, are there |\n| 18 | any other creditors on the line who have counsel |\n| 19 | who'd like to put their appearance on the record? |\n| 20 | MS. GRINNELL:
Hi -- |\n| 21 | MS. CLAIBORN:
Please wait for the |\n| 22 | translation. |\n| 23 | MS. GRINNELL:
(Indiscernible) I'm from |\n| 24 | the firm Wolf Haldenstein Adler Freeman and Herz and |\n| 25 | we represent -- |\n\n| Case 22-50073 | Doc 404-7
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6 |\n| 1 | THE INTERPRETER:
Sorry.
The interpreter |\n| 2 | cannot hear you clearly. |\n| 3 | MS. GRINNELL:
I'm sorry. My connection |\n| 4 | has been kind of off.
Can you hear me now? |\n| 5 | THE INTERPRETER: Yes. |\n| 6 | MS. GRINNELL:
Okay.
I'll repeat what I |\n| 7 | said. |\n| 8 | My name is Lillian Grinnell.
I'm an |\n| 9 | attorney at Wolf Haldenstein Adler Freeman and Herz |\n| 10 | and we represent the creditors, Rong Zhang, Xiaodan |\n| 11 | Wang, and Chong Sheen Raphanella. |\n| 12 | THE INTERPRETER:
The names you pronounced |\n| 13 | I could not get them. |\n| 14 | MS. GRINNELL:
I'll spell them. |\n| 15 | I'll start with the creditor's names.
The |\n| 16 | creditor's names are Rong Zhang, and that's -- the |\n| 17 | first name is Rong, R-O-N-G, Z-H-A-N-G. |\n| 18 | The second creditor's name is Xiaodan |\n| 19 | Wang.
And her first name is spelled X-I-A-O-D-A-N. |\n| 20 | And her last name is spelled W-A-N-G. |\n| 21 | And then the third creditor, Chong Shen |\n| 22 | Raphanella.
And her first name is C-H-O-N-G. And |\n| 23 | then the second name is S-H-E-N.
And the third name |\n| 24 | is R-A-P-H-A-N-E-L-L-A. |\n| 25 | THE INTERPRETER:
I only got Chong Shen |\n\n Ho Wan Kwok - March 21, 2022 7 1 and R-A-P-H-A-L. 2 MS. GRINNELL: I'm sorry. Are you asking 3 me to spell the third name again? 4 (No response.) 5 Sorry? I apologize. My connection is 6 very bad. Do you need me to spell any of the names 7 again? 8 THE INTERPRETER: I think I'm okay. I 9 repeat it to Mr. Kwok already. 10 MS. GRINNELL: Okay. 11 MS. CLAIBORN: Are there any other 12 creditors on the line or parties on the line? 13 MS. ZAMIR: This is Amy Zamir, from 14 Nessenoff & Miltenberg. I'm spell that. My last 15 name is Zamir, Z-A-M-I-R. Nessenoff is N-E-S-S-E-N-16 O-F-F, and Miltenberg, M-I-L-T-E-N-B-E-R-G. And we 17 represent creditor Sam Nunberg, N-U-N-B-E-R-G. 18 MS. CLAIBORN: Is there anyone else who 19 would like to put their appearance on the record. 20 MS. KUZNICK: Yes. This is Emily Kuznick, 21 E-M-I-L-Y, and then Kuznick, K-U-Z-N-I-C-K, of 22 Stroock, Stroock and Lavan, that's S-T-R-O-O-C-K, 23 and Stroock, and Lavan is L-A-V-A-N. And we 24 represent the Sherry Netherland. And for Sherry 25 Netherland it's S-H-E-R-R-Y, and then Netherland, N-\n\n Ho Wan Kwok - March 21, 2022 8 1 E-T-H-E-R-L-A-N-D. 2 THE INTERPRETER: I'm clarifying what he 3 said. 4 (Interpretation.) 5 THE INTERPRETER: Let me continue 6 clarifying what was yelled out just now. 7 (Interpretation.) 8 THE INTERPRETER: I'm sorry. The 9 interpreter cannot get that. Nobody picked up my 10 question so I don't know. 11 MS. CLAIBORN: Thank you, Bin. 12 Any other creditors or parties in interest 13 before I go back to the debtor? 14 MR. HARBACH: This is David Harbach, from 15 O'Melveny and Myers, representing PACS. I just 16 wanted to clarify that is it correct that we have 17 not gotten an answer from the debtor about what he 18 just said? 19 I have not heard any interpretation of it 20 and I understand the interpreter was attempting to 21 clarify what was said but the debtor did not 22 respond, as far as I heard, and we'd like to know 23 what he said. 24 MR. BALDIGA: This is Bill Baldiga. I'll 25 accept your apologies. That was not the debtor, but\n\n| Case 22-50073 | Doc 404-7
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9 |\n| 1 | I accept your apology for that inference. |\n| 2 | MS. CLAIBORN:
I'm going to come back to |\n| 3 | that a in minute. |\n| 4 | MR. HARBACH:
Okay.
(Indiscernible) |\n| 5 | whether I should apologize, but can we inquire then |\n| 6 | who made the outburst?
The interpreter was |\n| 7 | attempting to clarify and so are we.
Forgive the |\n| 8 | inference. |\n| 9 | THE INTERPRETER:
So I interpreted what |\n| 10 | you requested.
Just now someone burst out with a |\n| 11 | few words -- with sentences.
The interpreter did |\n| 12 | not get those sentences.
So the interpreter tried |\n| 13 | to clarify who talked and what those words are, but |\n| 14 | nobody picked up the interpreter's question. |\n| 15 | MS. CLAIBORN:
This is Holley Claiborn. |\n| 16 | Could the person who spoke up please answer the |\n| 17 | interpreter's question and identify themselves? |\n| 18 | THE INTERPRETER:
Sorry about that.
Just |\n| 19 | now it was it was just a video tape. It was not |\n| 20 | someone talked. |\n| 21 | MR. BALDIGA:
This is Bill Baldiga.
Mr. |\n| 22 | Kwok -- what Mr. Kwok heard during that outburst was |\n| 23 | someone playing back an audio of his voice and we do |\n| 24 | want to know everyone who is on the phone and we |\n| 25 | would like identified who played that audio clip. |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 11 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\n10\n\n| | Ho Wan Kwok - March 21, 2022
10 |\n|----|-------------------------------------------------------|\n| 1 | Thank you. |\n| 2 | UNIDENTIFIED:
Sorry, it was me. I played |\n| 3 | Mr. Kwok's video just now. |\n| 4 | MS. CLAIBORN:
Could the person who just |\n| 5 | spoke identify themselves? |\n| 6 | THE INTERPRETER:
The interpreter needs to |\n| 7 | clarify. |\n| 8 | (Interpreter inquires) |\n| 9 | MR. YAN:
My name is Xingyu Yan. I'm one of |\n| 10 | Mr. Kwok's creditors. |\n| 11 | MR. BALDIGA:
Can we have the spelling, |\n| 12 | please?
Could we obtain the spelling of that name |\n| 13 | please? |\n| 14 | MR. YAN:
The spelling is X, for Xray, I, as |\n| 15 | India, N, as in Nancy, G as in George, Y as in Yes, |\n| 16 | U as in umbrella.
Last name Y, A as in apple, N as |\n| 17 | in Nancy. |\n| 18 | MR. BALDIGA:
Ms. Claiborn, Bill Baldiga |\n| 19 | again.
Could you please exhaust the names of |\n| 20 | everyone else on the line, just so we know who is |\n| 21 | participating, whether or not they intend to ask |\n| 22 | questions? |\n| 23 | MS. CLAIBORN:
I'm trying to get there. |\n| 24 | That was my -- okay. |\n| 25 | Is anyone else on the line?
If you are on |\n\n| Case 22-50073 | Doc 404-7
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11 |\n| 1 | the line, and you could please identify yourself? |\n| 2 | MR. GREIF:
Hello.
My name is Steven Greif, |\n| 3 | G-R-E-I-F. |\n| 4 | MR. WARREN:
Steven Warren of O'Melveny & |\n| 5 | Myers. |\n| 6 | MR. JALBERT:
Craig Jalbert of |\n| 7 | (indiscernible). |\n| 8 | INDISCERNIBLE:
(Indiscernible)
from |\n| 9 | Robinson and Cole. |\n| 10 | INDISCERNIBLE:
(Indiscernible)
from |\n| 11 | Stroock, Stroock and Lavan. |\n| 12 | MS. DEERING:
Alexandra Deering of Brown |\n| 13 | Rudnick. |\n| 14 | MS. CLAIBORN:
This is Holley Claiborn |\n| 15 | again. Thank you all for putting your appearances on |\n| 16 | the record.
And if I could go back to debtor's |\n| 17 | camp, Mr. Baldiga, could you put your appearance on |\n| 18 | the record and note everybody who's with you at your |\n| 19 | location. |\n| 20 | MR. BALDIGA:
Yes.
We're in our -- |\n| 21 | I'm sorry. I missed what was just said. |\n| 22 | MS. CLAIBORN:
Mr. Baldiga, could you go |\n| 23 | ahead, please?
Mr. Baldiga, could you go ahead, |\n| 24 | please? |\n| 25 | MR. BALDIGA:
Yes.
Thank you.
We are at |\n\n83\n\n| Ho Wan Kwok - March 21, 2022
12 |\n|-----------------------------------------------------|\n| our offices at 7 Times Square in New York. |\n| And can you please state the name, Mr. |\n| Baldiga, of who is present with you? |\n| (No response.) |\n| MS. CLAIBORN:
Mr. Baldiga, could you please |\n| state the names of the people who are with you? |\n| MR. BALDIGA:
Ben Silverberg and Uri Pinelo. |\n| MS. CLAIBORN:
Okay.
Other names I believe |\n| I heard earlier are Una Menye (ph), who is an |\n| interpreter, and Attorney Aaron Mitchell. |\n| MR. BALDIGA:
That's right.
Yes. |\n| Ms. CLAIBORN:
Okay. I'm going to swear in |\n| Mr. Kwok and I would ask everyone to put their |\n| phones on mute. |\n| (The debtor is sworn.) |\n| MS. CLAIBORN: Mr. Kwok, as you know, today's |\n| meeting is being recorded and there's an |\n| interpreter, Bin, who's interpreting my questions |\n| and the comments of others and will also be |\n| interpreting your answers. |\n| Please wait to answer any questions you are |\n| asked today until the official interpreter has made |\n| a full translation. |\n| I ask that you do not communicate with your |\n| own interpreter who is present with you before you |\n| |\n\n| Case 22-50073 | Doc 404-7
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13 |\n| 1 | answer the questions, and should you do so, I will |\n| 2 | ask the official interpreter to translate that |\n| 3 | discussion. |\n| 4 | THE INTERPRETER:
Sorry.
Could you please |\n| 5 | repeat? |\n| 6 | MS. CLAIBORN:
Mr. Kwok, I ask that you do |\n| 7 | not communicate with your own interpreter who is |\n| 8 | with you today before you answer my questions or the |\n| 9 | questions of others. |\n| 10 | THE INTERPRETER:
He could not use his own |\n| 11 | interpreter. |\n| 12 | MS. CLAIBORN:
Bin, could you translate that |\n| 13 | instruction for Mr. Kwok. |\n| 14 | MR. BALDIGA:
This is Bill Baldiga. |\n| 15 | To the extent -- |\n| 16 | MS. CLAIBORN:
Mr. Baldiga, could you just |\n| 17 | wait for Bin to interpret that instruction for me |\n| 18 | and then you can make your comment. |\n| 19 | MR. BALDIGA:
Two things.
This is Bill |\n| 20 | Baldiga. |\n| 21 | Holley, you've become quite muffled again |\n| 22 | and second, to the extent that Mr. Kwok needs to |\n| 23 | talk to his interpreter to better understand what |\n| 24 | was said or the interpreter in the room with us |\n| 25 | believes that there was a misinterpretation, we will |\n\n| Doc 404-7
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Page 15 of | Case 22-50073 |\n|------------------------------------------------------------------------|---------------|\n|------------------------------------------------------------------------|---------------|\n\n Ho Wan Kwok - March 21, 2022 83\n\n| tell you that so that you do know if there is a |\n|--------------------------------------------------------|\n| further conversation. |\n| MS. CLAIBORN:
Thank you. |\n| HO WAN KWOK, Sworn |\n| EXAMINATION BY MS. CLAIBORN: |\n| Q
Mr. Kwok, can you please explain the reason |\n| to file your Chapter 11 bankruptcy case? |\n| UNIDENTIFIED:
Sorry? |\n| Q
Mr. Kwok, please explain the reasons behind |\n| your decision to file your Chapter 11 bankruptcy |\n| case? |\n| MR. HARBACH:
This is David Harbach.
We're |\n| having trouble understanding you again. |\n| MS. CLAIBORN:
I apologize.
My phone system |\n| is new and I'm yelling into the phone, but unless I |\n| put it on speaker phone I won't be able to record |\n| it.
Does yelling improve your ability to hear me? |\n| MR. HARBACH:
It's very difficult to |\n| understand your questions because they're so |\n| muffled.
It's not volume, it's diction, if I may be |\n| blunt. |\n| MS. CLAIBORN:
I will try to speak slowly. |\n| Is that any better? |\n| MR. BALDIGA:
It seems to be, yes.
Thank |\n| you. |\n| |\n\n| Case 22-50073 | Doc 404-7
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15 |\n| 1 | |\n| 2 | Q
Okay.
We're going to try this again. |\n| 3 | Mr. Kwok, can you please explain your |\n| 4 | reasons behind filing your Chapter 11 bankruptcy |\n| 5 | case? |\n| 6 | A
I cannot understand you.
I don't know what |\n| 7 | you mean by filing Chapter 11 of bank. |\n| 8 | Q
Mr. Kwok, why did you file your bankruptcy |\n| 9 | case? |\n| 10 | THE INTERPRETER:
The interpreter would like |\n| 11 | to clarify the word he said. |\n| 12 | A
I'm not filing any bankruptcy certificate. |\n| 13 | Q
Let me try again. |\n| 14 | Mr. Kwok, you are a Chapter 11 debtor in a |\n| 15 | bankruptcy proceeding here in the United States. |\n| 16 | Mr. Kwok, what were the reasons behind your |\n| 17 | decision to file your bankruptcy case? |\n| 18 | A
So you're asking me why I'm applying for |\n| 19 | bankruptcy, right? |\n| 20 | Q
Yes. |\n| 21 | A
I filed (indiscernible)
in mid-February in |\n| 22 | my second trial, or second appearance in Southern |\n| 23 | District. I was given a fine of \\$120 million and I |\n| 24 | was ordered to pay it off within five days.
So |\n| 25 | without any choices -- so I filed bankruptcy |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 17 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\n| | Ho Wan Kwok - March 21, 2022
16 |\n|----|-------------------------------------------------------|\n| 1 | application at Connecticut state and Chapter 11. |\n| 2 | Q
Mr. Kwok, when was the first time you spoke |\n| 3 | with a lawyer about filing a bankruptcy case? |\n| 4 | MR. BALDIGA:
Just the date, or the |\n| 5 | approximate date.
Not the substance of the advice. |\n| 6 | A
Approximately 12, 13. |\n| 7 | Q
Can you please provide the month and the |\n| 8 | year? |\n| 9 | A
It was February the 12th of 2002. |\n| 10 | Q
Did you say 2002 or 2021? |\n| 11 | A
2022.
February the 12th or 13. |\n| 12 | Q
Mr. Kwok, I'd ask you to take a look at your |\n| 13 | bankruptcy petition that was filed with the |\n| 14 | bankruptcy court at ECF 1. |\n| 15 | Mr. Kwok, a handwritten signature appears on |\n| 16 | that petition. Is that your handwritten signature? |\n| 17 | A
Hold on a second. I'll ask the lawyer to get |\n| 18 | it and I'll take a look. |\n| 19 | MR. BALDIGA:
This is Bill Baldiga.
We have |\n| 20 | with us the petition with the electronic signature |\n| 21 | as filed.
I don't have in the conference room me |\n| 22 | the handwritten signature.
If you'd like us to get |\n| 23 | it, we could get it at a break. |\n| 24 | Q
Mr. Kwok, can you take a look at the |\n| 25 | document that your counsel has, which is the |\n\n| Case 22-50073 | Doc 404-7
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17 |\n| 1 | bankruptcy petition with your printed name on it and |\n| 2 | confirm that you signed that document prior to it |\n| 3 | being filed with the court? |\n| 4 | A
Please hold on one second.
Let me take a |\n| 5 | look. |\n| 6 | MR. BALDIGA:
Could I hear the translation, |\n| 7 | please.
I want to hear the translation of what you |\n| 8 | said. |\n| 9 | (No response.) |\n| 10 | MR. BALDIGA:
Is the translator still with |\n| 11 | us? |\n| 12 | MS. CLAIBORN:
Bin, are you on the line? |\n| 13 | (No response.) |\n| 14 | Bin, are you there? |\n| 15 | (No response.) |\n| 16 | It seems that Bin has left us so I'm going |\n| 17 | to put everybody on hold and I'm going to try to |\n| 18 | reconnect her. I apologize. |\n| 19 | MR. BALDIGA:
That's okay.
Could we take a |\n| 20 | short break? |\n| 21 | MS. CLAIBORN:
It's going to take me a few |\n| 22 | minutes to do that, so go ahead and we'll reconvene |\n| 23 | as soon as I can get her on the line. |\n| 24 | MR. BALDIGA:
Thank you very much. |\n| 25 | (Off the record.) |\n\n| Case 22-50073 | Doc 404-7
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18 |\n| 1 | MS. CLAIBORN:
We are back on the record |\n| 2 | after a short break due to some technical |\n| 3 | difficulties. |\n| 4 | BY MS. CLAIBORN: |\n| 5 | Q
The pending question was asking Mr. Kwok to |\n| 6 | confirm that he signed the bankruptcy petition that |\n| 7 | was filed at ECF 1. |\n| 8 | A
I have finished looking at it, yes. |\n| 9 | Q
Mr. Kwok, did you read and understand the |\n| 10 | bankruptcy petition and information it contains |\n| 11 | before you signed it? |\n| 12 | A
Yes, I understood. |\n| 13 | Q
Mr. Kwok, was the petition translated into |\n| 14 | another language for you before you signed it? |\n| 15 | A
Yes, it was translated into Chinese for me. |\n| 16 | Q
Who translated the bankruptcy petition? |\n| 17 | A
My lawyer did. |\n| 18 | Q
Mr. Kwok, I don't think that Mr. Baldiga |\n| 19 | speaks Chinese. |\n| 20 | So who was the company or the person that |\n| 21 | you used to translate the petition for you? |\n| 22 | A
I don't know. |\n| 23 | Q
Mr. Kwok, is the information in your |\n| 24 | bankruptcy petition true and accurate to the best of |\n| 25 | your knowledge? |\n\n| Case 22-50073 | Doc 404-7
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19 |\n| 1 | A
Yes, it is accurate and true. |\n| 2 | Q
Mr. Kwok, can you please take a look at the |\n| 3 | declaration and about individual debtor's schedules |\n| 4 | that was filed with the court docket at ECF No. 79. |\n| 5 | THE INTERPRETER:
Sorry, could you please |\n| 6 | repeat? |\n| 7 | Q
Mr. Kwok, can you please take a look at the |\n| 8 | declaration about an individual debtor's schedules |\n| 9 | that was filed with the bankruptcy court at ECF 79. |\n| 10 | Mr. Kwok, a handwritten signature appears on |\n| 11 | that declaration. Is that your handwritten |\n| 12 | signature? |\n| 13 | A
The document in my hand.
Yes, it was signed |\n| 14 | by me. |\n| 15 | Q
And are you looking at ECF no. 79? |\n| 16 | A
Yes. |\n| 17 | Q
Mr. Kwok, was the declaration that was filed |\n| 18 | at ECF 79 translated into another language for you |\n| 19 | before you signed it? |\n| 20 | A
Yes. |\n| 21 | Q
What language was it translated into? |\n| 22 | A
Chinese. |\n| 23 | Q
Mr. Kwok, do you know who did the |\n| 24 | translation of ECF no. 79? |\n| | |\n\n25 A Yes.\n\n| Case 22-50073 | Doc 404-7
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20 |\n| 1 | Q
And who was that person who translated ECF |\n| 2 | 79 into Chinese for you? |\n| 3 | A
The lawyer. |\n| 4 | Q
Can you tell me the name of the lawyer? |\n| 5 | A
Bill. |\n| 6 | MR. BALDIGA:
This is Bill Baldiga.
The |\n| 7 | witness is not distinguishing between what I did |\n| 8 | personally and what we had commissioned, to help |\n| 9 | clarify.
I do not obviously do translations myself. |\n| 10 | MS. CLAIBORN:
Attorney Baldiga, can you |\n| 11 | tell me the name of the translation person who |\n| 12 | worked for you or the name of the company? |\n| 13 | MR. BALDIGA:
I'll have to get that. I don't |\n| 14 | have it here. |\n| 15 | Q
Mr. Kwok, did you read and understand the |\n| 16 | declaration filed at ECF no. 79 before you signed |\n| 17 | it? |\n| 18 | A
Yes, understood. |\n| 19 | Q
Mr. Kwok, can you please take a look at your |\n| 20 | bankruptcy schedules that were filed with the |\n| 21 | bankruptcy court at ECF 78. |\n| 22 | And Mr. Kwok, for purposes of today, when I |\n| 23 | used the term schedules, either collectively or by a |\n| 24 | particular schedule, I'm referring to the documents |\n| 25 | that were filed at ECF 78. |\n\n| Case 22-50073 | Doc 404-7
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83 | Entered 05/20/22 11:52:18 | Page 22 of |\n|---------------|------------------------------------------------------|----------------------------------------------|------------|\n| | Ho Wan Kwok - March 21, 2022 | | 21 |\n| 1 | | Mr. Kwok, were your bankruptcy schedules | |\n| 2 | translated for you? | | |\n| 3 | A
Yes, it was translated. | | |\n| 4 | Q | Mr. Kwok, were you involved in preparing the | |\n| 5 | responses and the answers to the questions in the | | |\n| 6 | schedules? | | |\n| 7 | A
Yes, I was. | | |\n| 8 | Q | Mr. Kwok, did you read and understand all of | |\n| 9 | the responses and the answers to the questions in | | |\n| 10 | the schedules before you signed the declaration that | | |\n| 11 | was filed at ECF 79. | | |\n| 12 | A
Yes. | | |\n| 13 | Q | Mr. Kwok, who assisted you in the | |\n| 14 | preparation of your bankruptcy schedules? | | |\n| 15 | A
The lawyer. | | |\n| 16 | Q | Mr. Kwok, can you tell me which lawyers | |\n| 17 | helped you? | | |\n| 18 | A
Bill. | | |\n| 19 | Q | Mr. Kwok, are you referring to Attorney | |\n| 20 | Baldiga? | | |\n| 21 | A
Yes. | | |\n| 22 | Q | Mr. Kwok, did any other lawyers help you in | |\n| 23 | preparing your bankruptcy schedules? | | |\n| 24 | A
Yes. | | |\n| 25 | Q | Can you please tell me the names of the | |\n\n| Case 22-50073 | Doc 404-7
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22 |\n| 1 | other lawyers who assisted you? |\n| 2 | A
I don't know how to say their names. I |\n| 3 | cannot read English well. |\n| 4 | MR. BALDIGA:
This is Bill Baldiga. I'm |\n| 5 | happy to add that, of course, other of our |\n| 6 | colleagues here at Brown Rudnick assisted. But I'm |\n| 7 | not sure Mr. Kwok would have details as to who |\n| 8 | exactly assisted on what part of it, but you could |\n| 9 | ask, of course. |\n| 10 | Q
Mr. Kwok, did any lawyer help you prepare |\n| 11 | your schedules who is not a lawyer at Brown Rudnick? |\n| 12 | MR. BALDIGA:
Excuse me. I need to talk with |\n| 13 | Mr. Kwok for one second. I'm just going to put you |\n| 14 | on mute for one second. |\n| 15 | MS. CLAIBORN:
I'd prefer he answer the |\n| 16 | question before you have your conference, Mr. |\n| 17 | Baldiga. |\n| 18 | A
Because the whole bankruptcy application, |\n| 19 | the whole stuff was arranged by this lawyer.
But I |\n| 20 | don't know all the other details. |\n| 21 | MS. CLAIBORN:
Do you want to confer with |\n| 22 | your client? |\n| 23 | MR. BALDIGA:
I'll clarify only that Mr. |\n| 24 | Kwok likely does not know of all of the |\n| 25 | conversations that we've had with others, but this |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 24 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\n| 23 |\n|----|\n| |\n\n| | Ho Wan Kwok - March 21, 2022
23 |\n|----|------------------------------------------------------|\n| 1 | is the opportunity to exam him, so you can obviously |\n| 2 | ask that but we don't want to be misleading. |\n| 3 | Q
Mr. Kwok, aside from Mr. Baldiga and lawyers |\n| 4 | at Brown Rudnick did you speak with any other |\n| 5 | lawyers about preparing your bankruptcy schedules? |\n| 6 | A
Yes. |\n| 7 | Q
Who did you speak with? |\n| 8 | A
Another law firm called Ari and my personal |\n| 9 | lawyer (indiscernible). |\n| 10 | Q
What is the name of your personal lawyer? |\n| 11 | MR. BALDIGA:
Could I confer and I might be |\n| 12 | able to answer that question? |\n| 13 | MS. CLAIBORN:
Go ahead. |\n| 14 | MR. BALDIGA:
Could I have a second to |\n| 15 | confer, please? |\n| 16 | MS. CLAIBORN:
Yes. |\n| 17 | (Pause.) |\n| 18 | MR. BALDIGA:
Thank you. |\n| 19 | Q
Mr. Kwok, what is the name of your personal |\n| 20 | lawyer? |\n| 21 | A
Guy Petrillo and
Ari (indiscernible). |\n| 22 | Q
Mr. Kwok do I understand correctly that you |\n| 23 | discussed your bankruptcy schedules with Guy |\n| 24 | Petrillo and Aaron Mitchell? |\n| 25 | A
Yes. |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 25 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\nHo Wan Kwok - March 21, 2022\n\n| 1 | Q
Mr. Kwok, did you discuss your bankruptcy |\n|----|-----------------------------------------------------|\n| 2 | schedules with any other lawyers that you haven't |\n| 3 | yet told me about today? |\n| 4 | A
I don't remember. |\n| 5 | Q
Mr. Kwok, are there any errors or omissions |\n| 6 | in your bankruptcy schedules? |\n| 7 | A
I don't see anything like that now. |\n| 8 | Q
Mr. Kwok, is everything in your bankruptcy |\n| 9 | schedules true and accurate to the best of your |\n| 10 | knowledge? |\n| 11 | A
Yes. |\n| 12 | Q
Mr. Kwok, could you please take a look at |\n| 13 | your bankruptcy statement of financial affairs that |\n| 14 | was filed with the court at ECF no. 77. |\n| 15 | Mr. Kwok, using the numbers at the top of |\n| 16 | the document can you please go to page 20 where you |\n| 17 | will find a handwritten signature. |\n| 18 | THE INTERPRETER: Sorry? |\n| 19 | Q
Where you will find a handwritten signature. |\n| 20 | Mr. Kwok, is the handwritten signature on |\n| 21 | page 20 of the statement of financial affairs your |\n| 22 | own? |\n| 23 | A
Yes. |\n| 24 | Q
Mr. Kwok, was the statement of financial |\n| 25 | affairs translated for you before you signed it? |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22
83 | Entered 05/20/22 11:52:18 | Page 26 of |\n|---------------|------------|---------------------------------|------------------------------------------------------|------------|\n| | | Ho Wan Kwok - March 21, 2022 | | 25 |\n| 1 | A | Yes. | | |\n| 2 | Q | | Mr. Kwok, were you involved in the preparing | |\n| 3 | | | of the responses and the answers to the questions in | |\n| 4 | | | the statement of financial affairs? | |\n| 5 | A | Yes. | | |\n| 6 | Q | | Mr. Kwok, did you read and understand all | |\n| 7 | | | the responses and answers to the questions in the | |\n| 8 | | | statement of financial affairs before you signed it? | |\n| 9 | A | I understood all. | | |\n| 10 | Q | | Mr. Kwok, are there any errors or omissions | |\n| 11 | | | in your statement of financial affairs? | |\n| 12 | A | No. | | |\n| 13 | | (No response.) | | |\n| 14 | Q | | Mr. Kwok, would you please answer the | |\n| 15 | question? | | | |\n| 16 | | MR. BALDIGA: | I'm sorry.
Could you repeat | |\n| 17 | that? | | We didn't get the interpretation here in the | |\n| 18 | | room for some reason. | | |\n| 19 | | MS. CLAIBORN: | I'll ask the question again. | |\n| 20 | Q | | Are there any errors or omissions in your | |\n| 21 | | statement of financial affairs? | | |\n| 22 | A | | Up to now I haven't found any errors or | |\n| 23 | omissions. | | | |\n| 24 | Q | | Mr. Kwok, is everything in your statement of | |\n| 25 | | | financial affairs true and accurate to the best of | |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22
83 | Entered 05/20/22 11:52:18 | Page 27 of |\n|---------------|-----------------|------------------------------|------------------------------------------------------|------------|\n| | | Ho Wan Kwok - March 21, 2022 | | 26 |\n| 1 | your knowledge? | | | |\n| 2 | A | Yes. | | |\n| 3 | Q | | Mr. Kwok, who assisted you in the | |\n| 4 | | | preparation of your statement of financial affairs? | |\n| 5 | A | | My lawyer, Bill, and my financial advisor, | |\n| 6 | Matt. | | | |\n| 7 | Q | | Mr. Kwok, are you referring to Attorney | |\n| 8 | Baldiga? | | | |\n| 9 | A | Yes. | | |\n| 10 | Q | | And what is the name -- the full name of the | |\n| 11 | | financial advisor? | | |\n| 12 | A | | I don't know how to spell it. | |\n| 13 | | MR. BALDIGA: | It's Matt Flynn and colleagues | |\n| 14 | | at Verdolino and Lowey. | But you could -- | |\n| 15 | Q | Mr. Kwok, is that correct? | | |\n| 16 | A | | I'm afraid I will say it wrong, but I will | |\n| 17 | | | ask for Mr. -- my lawyer Baldiga to clarify for you. | |\n| 18 | Q | We can move on. | | |\n| 19 | | MR. BALDIGA: | This is Bill Baldiga. | |\n| 20 | | | Mr. Kwok simply does not know the full name | |\n| 21 | | | of Matt Flynn or Matt's colleagues at Verlino and | |\n| 22 | | | Lowey, but I confirm that he is pointing at Matt | |\n| 23 | | | Flynn next to him when he answers the question. | |\n| 24 | | MS. CLAIBORN: | Thank you. | |\n| 25 | Q | | Mr. Kwok, did anyone else help you with your | |\n\n| Case 22-50073 | Doc 404-7
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27 |\n| 1 | statement of financial affairs? |\n| 2 | A
No. |\n| 3 | Q
Mr. Kwok, how long have you lived in the |\n| 4 | United States? |\n| 5 | A
Nearly seven years. |\n| 6 | MR. HARBACH:
This is David Harbach.
I |\n| 7 | didn't get the translation of the answer. |\n| 8 | MS. CLAIBORN:
Bin, can you please repeat |\n| 9 | your translation. |\n| 10 | THE INTERPRETER:
Nearly 7 years. |\n| 11 | Q
Mr. Kwok, do you still live at the Taconic |\n| 12 | Road property in Greenwich? |\n| 13 | A
Yes. |\n| 14 | Q
Who owns that property in Greenwich? |\n| 15 | A
My wife. |\n| 16 | Q
Your bankruptcy documents refer to a company |\n| 17 | called Greenwich Land, LLC.
Who owns that company? |\n| 18 | A
My wife. |\n| 19 | Q
What is your wife's name? |\n| 20 | A
(Indiscernible) |\n| 21 | MS. CLAIBORN:
Bin, could you please |\n| 22 | translate that for me into a spelling? |\n| 23 | THE INTERPRETER:
Let me just clarify with |\n| 24 | him which Chinese characters are, then I can spell |\n| 25 | it for you. |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22
83 | Entered 05/20/22 11:52:18 | Page 29 of |\n|---------------|------------|------------------------------|------------------------------------------------------|------------|\n| | | Ho Wan Kwok - March 21, 2022 | | 28 |\n| 1 | A | | My wife's name is read at (indiscernible) | |\n| 2 | | | but she's from -- she's from Hong Kong.
Their | |\n| 3 | | | spelling is different from Mainland and I don't know | |\n| 4 | | how to spell her name. | | |\n| 5 | Q | | Mr. Kwok, could you just please spell her | |\n| 6 | last name? | | | |\n| 7 | A | I don't know how to spell. | | |\n| 8 | Q | | Does anyone else have a membership interest | |\n| 9 | | | in Greenwich Land LLC aside from your wife? | |\n| 10 | A | I don't know. | | |\n| 11 | Q | | When was Greenwich Land LLC formed as a | |\n| 12 | company? | | | |\n| 13 | A | 2020. | | |\n| 14 | Q | | Mr. Kwok, have you ever been a member of | |\n| 15 | | Greenwich Land, LLC? | | |\n| 16 | A | No. | | |\n| 17 | Q | | How much did Greenwich Land, LLC pay for the | |\n| 18 | | | purchase of the Greenwich property on Taconic Road? | |\n| 19 | A | | I don't know specifically but approximately | |\n| 20 | 5 million. | | | |\n| 21 | Q | | And how was that purchase funded? | |\n| 22 | A | I don't know. | | |\n| 23 | Q | | Who would know the answer, Mr. Kwok? | |\n| 24 | | THE INTERPRETER: | Sorry? | |\n| 25 | Q | | Who would know the answer to that, Mr. Kwok? | |\n\n| Case 22-50073 | Doc 404-7
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29 |\n| 1 | A
My wife knows. |\n| 2 | MR. HARBACH:
This is David Harbach and I |\n| 3 | apologize for the interruption. |\n| 4 | We missed the translation by the number of |\n| 5 | that Mr. Kwok said approximately this kind of |\n| 6 | property would cost.
Could that please be repeated? |\n| 7 | THE INTERPRETER:
Sorry, the interpreter |\n| 8 | cannot hear you clearly. |\n| 9 | MS. CLAIBORN:
Mr. Harbach, I will ask your |\n| 10 | question again. |\n| 11 | MR. HARBACH:
Thank you. |\n| 12 | Q
How much was the Taconic Road property in |\n| 13 | Greenwich purchased for? |\n| 14 | A
I don't know clearly but approximately 4 |\n| 15 | million to 5 million. |\n| 16 | Q
When did Greenwich Land LLC purchase the |\n| 17 | property on Taconic Road in Greenwich? |\n| 18 | A
I don't know the specific time. |\n| 19 | Q
Do you know the year? |\n| 20 | A
2019 or 2020. I don't remember clearly. |\n| 21 | (Unintelligible background chatter.) |\n| 22 | MS. CLAIBORN:
Could whoever is speaking |\n| 23 | identify themselves? |\n| 24 | MR. BALDIGA:
Excuse me just for one second. |\n| 25 | We may have a translation issue.
I'm just going to |\n\n Ho Wan Kwok - March 21, 2022 30 1 put you on mute for one second. 2 (Pause.) 83\n\n3 MR. BALDIGA: This is Bill Baldiga. We 4 believe that the answer by Mr. Kwok to the date was 5 2019 or 2020, but the translator may have said 2020 6 without a mention of 2019. I obviously don't know. 7 But that's -- if it matters, you could re-ask to be 8 sure that there's clarity around that?\n\n9 Q Mr. Kwok, when did Greenwich Land LLC 10 purchase the Taconic Road property in Greenwich? 11 A Maybe it's 2020 or maybe it's 2019. I don't 12 remember clearly. I don't know.\n\n13 Q Mr. Kwok, did you sign any documents in 14 connection with the purchase of the Taconic Road 15 Property in Greenwich?\n\n16 A No.\n\n17 Q Mr. Kwok, who lives at the Taconic Road 18 property in Greenwich?\n\n19 THE INTERPRETER: Sorry? Who -- 20 Q Who lives at the Taconic Road property in 21 Greenwich? 22 A My wife and I. Sometimes my daughter who 23 lives in New York will come back. 24 Q Mr. Kwok, are you currently employed by\n\n25 anyone?\n\n| Case 22-50073 | Doc 404-7
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83 |\n|---------------|------------------------------------------------------------------------------|\n| | Ho Wan Kwok - March 21, 2022
31 |\n| 1 | THE INTERPRETER:
Are you what? |\n| 2 | Q
Are you currently employed by anyone or any |\n| 3 | company? |\n| 4 | A
No. |\n| 5 | Q
Mr. Kwok, have you had any employment or any |\n| 6 | job with an employer since you started living in the |\n| 7 | United States? |\n| 8 | A
I don't remember clearly.
I don't remember |\n| 9 | clearly but approximately in 2015 at Golden Spring I |\n| 10 | worked for some time.
After I got part of my wages |\n| 11 | of salary I left and nothing else. |\n| 12 | Q
What work did you do for Golden Spring in |\n| 13 | 2015? |\n| 14 | A
I don't remember quite clearly but it seems |\n| 15 | it (indiscernible)
I was put in charge of |\n| 16 | developing (indiscernible)
investors. But I don't |\n| 17 | remember clearly. |\n| 18 | Q
Mr. Kwok, when did you stop working for |\n| 19 | Golden Spring? |\n| 20 | MR. BALDIGA:
Excuse me just one second. I |\n| 21 | just want to make sure we -- excuse me for one |\n| 22 | second. I just want to make sure we don't |\n| 23 | (indiscernible) translation.
We may. |\n| 24 | (Pause.) |\n| 25 | MR. BALDIGA:
Our interpreter believes that |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 33 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\n32\n\n| | Ho Wan Kwok - March 21, 2022
32 |\n|----|------------------------------------------------------|\n| 1 | the response was that if he had a role at Golden |\n| 2 | Springs, it was to develop investment opportunities |\n| 3 | not to develop investors. |\n| 4 | Q
Mr. Kwok, when did you stop working for |\n| 5 | Golden Spring? |\n| 6 | A
I don't remember clearly. |\n| 7 | Q
Mr. Kwok, when you say Golden Spring, are |\n| 8 | you referring to the company known as Golden Spring, |\n| 9 | New York, Limited? |\n| 10 | A
Yes. |\n| 11 | Q
Mr. Kwok, did you get paid for any of the |\n| 12 | work that you for Golden Spring? |\n| 13 | A
Yes. |\n| 14 | Q
How much were you paid? |\n| 15 | A
Approximately 200,000. I don't remember |\n| 16 | specifically. |\n| 17 | Q
Mr. Kwok, did you receive a paycheck from |\n| 18 | your work at Golden Spring? |\n| 19 | A
I should have but I don't remember clearly |\n| 20 | specifically. |\n| 21 | Q
Mr. Kwok, did you put the money that you |\n| 22 | were paid by Golden Spring into a bank account? |\n| 23 | A
I should have put it into a credit card |\n| 24 | account at Morgan Stanley. |\n| 25 | Q
Mr. Kwok, are you saying that you had a bank |\n\n| Case 22-50073 | Doc 404-7
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33 |\n| 1 | account at Morgan Stanley? |\n| 2 | A
Yes, once I had. |\n| 3 | Q
Do you still have a bank account at Morgan |\n| 4 | Stanley? |\n| 5 | A
No. |\n| 6 | Q
When did you close your accounts at Morgan |\n| 7 | Stanley? |\n| 8 | A
Around April, 2017 when (indiscernible)
the |\n| 9 | Chinese Communist Party stated chasing me and |\n| 10 | (indiscernible)
me.
So all my bank accounts were |\n| 11 | closed. |\n| 12 | MR. BALDIGA:
Hold on.
There's a |\n| 13 | mistranslation there. |\n| 14 | (Pause.) |\n| 15 | MR. BALDIGA:
The prior misstatement or |\n| 16 | mistranslation was just the interpretation of the |\n| 17 | word. But here the entire crux of the answer was |\n| 18 | left out.
And I'm not sure what happened. |\n| 19 | MS. CLAIBORN:
Maybe I can ask a different |\n| 20 | question. We can try again. |\n| 21 | MR. BALDIGA:
No, I think -- no, I think -- |\n| 22 | the answer -- I'm concerned with the accuracy of the |\n| 23 | translation because there was specific mention of |\n| 24 | names that were simply not produced in the answer. |\n| 25 | And I'll guess, Bin, did you not hear the mention of |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 35 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\nHo Wan Kwok - March 21, 2022\n\n83\n\n| 1 | PACS and Bruno Wu, or was there a sound issue, or |\n|----|---------------------------------------------------------|\n| 2 | what happened? |\n| 3 | (Interpreter translates) |\n| 4 | MS. CLAIBORN:
Mr. Kwok, did you -- |\n| 5 | MR. KWOK:
So Bruno Wu, (indiscernible) |\n| 6 | Airlines and also Chinese Communist party, they all |\n| 7 | chased me and wanted to kill me.
So I |\n| 8 | (indiscernible)
-- all my bank accounts were |\n| 9 | closed. |\n| 10 | PAC, PACS.
(Indiscernible)
all the people |\n| 11 | are present today at today's meeting. |\n| 12 | MR. BALDIGA:
Could we have on the record |\n| 13 | the entirety of what Mr. Kwok said.
That's a very |\n| 14 | small part of what he said, obviously.
I don't know |\n| 15 | what he said but that's much shorter. |\n| 16 | (Interpreter translates) |\n| 17 | THE INTERPRETER:
The interpreter is asking |\n| 18 | him to (indiscernible)
every two names so that I |\n| 19 | can maintain the integrity of his meaning. |\n| 20 | MR. KWOK:
At today's meeting there are PAC, |\n| 21 | one of the major creditors.
And also |\n| 22 | (indiscernible).
And also (indiscernible)
member. |\n| 23 | All the money that had to be paid went into an |\n| 24 | account of the Communist Party under the name of |\n| 25 | Bruno Wu.
So since that day when all the -- all the |\n\n| Case 22-50073 | Doc 404-7
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35 |\n| 1 | representatives of the Chinese Communist party -- so |\n| 2 | when the chasing and killing started I lost all my |\n| 3 | bank accounts. |\n| 4 | MR. HARBACH:
This is David Harbach.
Bin, |\n| 5 | could you please repeat that? |\n| 6 | THE INTERPRETER:
Sorry? |\n| 7 | MR. HARBACH:
This is David Harbach.
You |\n| 8 | just translated an answer that began with since that |\n| 9 | day.
Can you please repeat the answer in English? |\n| 10 | THE INTERPRETER:
Since that day all those |\n| 11 | people who are representatives of Chinese Communist |\n| 12 | Party, since that day I lost all my bank accounts. |\n| 13 | BY MS. CLAIBORN: |\n| 14 | Q
Mr. Kwok, did you have any money in your |\n| 15 | Morgan Stanley account when you closed it? |\n| 16 | A
Yes. |\n| 17 | Q
And where did you move that money to? |\n| 18 | A
Nobody bothered looking at me again since |\n| 19 | the account was closed. |\n| 20 | Q
Mr. Kwok, my question is where did you move |\n| 21 | the money to? |\n| 22 | MR. BALDIGA:
This is Bill Baldiga -- I'm |\n| 23 | sorry.
This is Bill Baldiga. |\n| 24 | Could you ask if perhaps you're inferring or |\n| 25 | implying that he moved it as opposed to something |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 37 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\nHo Wan Kwok - March 21, 2022\n\n| 1 | happened to it?
Could you ask it in a more neutral |\n|----|-------------------------------------------------------|\n| 2 | way and you may get a more full answer? |\n| 3 | Q
Mr. Kwok, did you or someone acting on your |\n| 4 | behalf close the Morgan Stanley account? |\n| 5 | A
The Communist Party, Bruno Wu and also the |\n| 6 | (indiscernible).
It was closed by the Communist |\n| 7 | party. |\n| 8 | Q
Mr. Kwok, was the Morgan Stanley account in |\n| 9 | the United States? |\n| 10 | A
Yes. |\n| 11 | Q
Mr. Kwok, how does somebody other than you, |\n| 12 | or someone acting on your behalf close a bank |\n| 13 | account in your name? |\n| 14 | THE INTERPRETER:
He wants me to repeat the |\n| 15 | question, the interpretation of the question. |\n| 16 | (Interpreter translates again.) |\n| 17 | A
It's the core control of the Communist |\n| 18 | Party, like what's happening today. The same thing. |\n| 19 | (Indiscernible)
happened on me. |\n| 20 | MR. BALDIGA:
Ms. Claiborn, could I suggest |\n| 21 | that you ask whether Morgan Stanley closed the |\n| 22 | account, just so we could be more efficient here? |\n| 23 | Q
Mr. Kwok, did you close the account at |\n| 24 | Morgan Stanley? |\n| 25 | THE INTERPRETER:
Sorry? |\n\n| Case 22-50073 | Doc 404-7
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83 |\n|---------------|------------------------------------------------------------------------------|\n| | Ho Wan Kwok - March 21, 2022
37 |\n| 1 | Q
Mr. Kwok, did you close the account at |\n| 2 | Morgan Stanley? |\n| 3 | THE INTERPRETER:
I'm sorry. I still didn't |\n| 4 | quite get the question actually. |\n| 5 | Q
Mr. Kwok, did you personally close the |\n| 6 | account at Morgan Stanley? |\n| 7 | A
No. |\n| 8 | Q
Mr. Kwok, did you ask someone at Morgan |\n| 9 | Stanley to close your account? |\n| 10 | A
No. |\n| 11 | Q
Mr. Kwok, how did you find out that your |\n| 12 | bank account at Morgan Stanley was closed? |\n| 13 | A
Morgan Stanley notified me that I was on the |\n| 14 | wanted list of the Chinese government.
So it was |\n| 15 | Bruno Wu who was representing (indiscernible)
name |\n| 16 | on the wanted list so the account was closed. |\n| 17 | Q
Mr. Kwok, when Morgan Stanley closed the |\n| 18 | account, what happened to the money in the account? |\n| 19 | MR. HARBACH:
Ms. Claiborn, this is David |\n| 20 | Harbach. I'm sorry. I missed the second half of that |\n| 21 | question.
When Morgan Stanley closed the account |\n| 22 | and then I lost you. |\n| 23 | Q
I'll repeat my question. |\n| 24 | Mr. Kwok, when Morgan Stanley closed the |\n| 25 | bank account, what happened to the money in the bank |\n\n| Case 22-50073 | Doc 404-7
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38 |\n| 1 | account? |\n| 2 | A
The last thing I know was a Chinese speaking |\n| 3 | person called me telling me that my account was |\n| 4 | closed because I was under a wanted list of the |\n| 5 | Chinese government.
And what happened later on I |\n| 6 | don't know really. |\n| 7 | Q
Mr. Kwok, how much money was in the -- |\n| 8 | MR. BALDIGA:
This is Bill Baldiga -- |\n| 9 | MS. CLAIBORN:
Yes, Mr. Baldiga? |\n| 10 | MR. BALDIGA:
This is Bill Baldiga. I think |\n| 11 | it would be helpful -- I don't want to interrupt |\n| 12 | your flow of questions, if we took a break pretty |\n| 13 | soon.
But if you want to finish this line, certain |\n| 14 | do that. |\n| 15 | I also want -- there may be some confusion |\n| 16 | with the Morgan name and so you may want to ask the |\n| 17 | witness whether it's, in fact, Morgan Stanley or JP |\n| 18 | Morgan Chase. |\n| 19 | MR. KWOK:
Now I remember. I think it was JP |\n| 20 | Morgan Chase.
I just cannot differentiate. I get |\n| 21 | confused with Morgan Stanley or JP Morgan Chase. |\n| 22 | Q
Mr. Kwok, was there only one account at |\n| 23 | whatever it is you're calling it, be it JP Morgan |\n| 24 | Chase or Morgan Stanley? |\n| 25 | A
What I remember is I have this only one |\n\n| Case 22-50073 | Doc 404-7
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39 |\n| 1 | account. |\n| 2 | Q
How much money was in that account |\n| 3 | approximately when it was closed? |\n| 4 | A
A few thousand U.S. dollars. |\n| 5 | MR. HARBACH:
I missed it. Can you repeat |\n| 6 | the English, please? |\n| 7 | MS. CLAIBORN:
Bin, can you please repeat |\n| 8 | the answer? |\n| 9 | (No response.) |\n| 10 | MS. CLAIBORN:
Bin, can you please repeat |\n| 11 | the answer? |\n| 12 | MR. HARBACH:
This is David Harbach. I |\n| 13 | missed the translation before the word thousand. I |\n| 14 | did not hear the number.
Could you please repeat |\n| 15 | it? |\n| 16 | THE INTERPRETER:
He said a few thousand |\n| 17 | U.S. dollars. |\n| 18 | Q
Mr. Kwok, when you say a few thousand |\n| 19 | dollars, can you give me an idea of what you mean? |\n| 20 | Was it under \\$10,000? |\n| 21 | A
I don't remember. |\n| 22 | Q
Mr. Kwok, a few minutes ago you testified |\n| 23 | that you were working for Golden Spring developing |\n| 24 | investment opportunities.
Can you explain more? |\n| 25 | THE INTERPRETER:
Sorry? |\n\n| Case 22-50073 | Doc 404-7
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40 | | | | | | |\n| 1 | MS. CLAIBORN:
I wasn't finished with the | | | | | | |\n| 2 | question. I apologize. I'll try again. | | | | | | |\n| 3 | Q
Mr. Kwok, a few minutes ago you testified | | | | | | |\n| 4 | that you were working for Golden Spring developing | | | | | | |\n| 5 | investment opportunities.
Can you please explain | | | | | | |\n| 6 | what you mean by that? | | | | | | |\n| 7 | A
I don't remember. | | | | | | |\n| 8 | Q
When you were working for Golden Spring, | | | | | | |\n| 9 | were you working in the United States? | | | | | | |\n| 10 | A
Yes. | | | | | | |\n| 11 | Q
When you were working with Golden Spring did | | | | | | |\n| 12 | you have a job title? | | | | | | |\n| 13 | A
I don't remember. | | | | | | |\n| 14 | Q
When you were working for Golden Spring, did | | | | | | |\n| 15 | you do any other work aside from developing | | | | | | |\n| 16 | investment opportunities? | | | | | | |\n| 17 | A
(indiscernible)
Communist Party of China. | | | | | | |\n| 18 | Q
Can you please explain that? | | | | | | |\n| 19 | A
Since 2015 up till now I have been spending | | | | | | |\n| 20 | all my time and my energy on collecting information | | | | | | |\n| 21 | about corruption and also human rights issues and | | | | | | |\n| 22 | assassinations of the Community Party.
That's my | | | | | | |\n| 23 | target and my work. | | | | | | |\n| 24 | Q
Mr. Kwok, do you currently have any source | | | | | | |\n\n25 of income?\n\n| Case 22-50073 | Doc 404-7
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41 |\n| 1 | THE INTERPRETER:
I didn't get you.
Could |\n| 2 | you please repeat? |\n| 3 | Q
Mr. Kwok, do you currently have a source of |\n| 4 | income? |\n| 5 | A
No. |\n| 6 | Q
Mr. Kwok, have you filed your tax returns |\n| 7 | for the year 2021 with the Internal Revenue Service |\n| 8 | in the United States? |\n| 9 | A
No. |\n| 10 | Q
Mr. Kwok, have you filed any tax returns in |\n| 11 | states for the tax year 2021? |\n| 12 | THE INTERPRETER:
Sorry? |\n| 13 | Q
Have you filed any tax returns for any |\n| 14 | states for the tax year 2021? |\n| 15 | A
No. |\n| 16 | Q
What tax returns will you need to file for |\n| 17 | what states for the year 2021? |\n| 18 | A
Individual tax file in Connecticut. |\n| 19 | Q
Will you be filing a tax return for the |\n| 20 | State of New York for the year 2021? |\n| 21 | A
No. |\n| 22 | Q
Mr. Kwok, you previously provided to my |\n| 23 | office tax returns for the years 2019 and 2020.
Are |\n| 24 | those tax returns the same as the tax returns you |\n| 25 | filed with the Internal Revenue Service in the State |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 43 of |\n|---------------|-----------|----------------|---------------------------|------------|\n| | | | | |\n\n Ho Wan Kwok - March 21, 2022 83\n\n| 1 | of New York? |\n|----|-------------------------------------------------------|\n| 2 | THE INTERPRETER:
Sorry, the date of what? |\n| 3 | MS. CLAIBORN:
2019 and 2020. |\n| 4 | THE INTERPRETER:
Yes, I got that.
What's |\n| 5 | the later part? |\n| 6 | MS. CLAIBORN:
The State of New York. |\n| 7 | A
No, I filed them in Connecticut, 2020. |\n| 8 | Q
Mr. Kwok -- |\n| 9 | A
I in (indiscernible)
for 2019 and 2020. |\n| 10 | 2020 I filed in Connecticut. |\n| 11 | MR. BALDIGA:
Holley, can we take a break |\n| 12 | soon? |\n| 13 | MS. CLAIBORN:
Unfortunately, I'm going to |\n| 14 | suggest that we can't really take a break because we |\n| 15 | only have the interpreter until 2:00.
So if we do, |\n| 16 | it needs to be a very, very short one. |\n| 17 | MR. BALDIGA:
Okay. Five minutes? |\n| 18 | MS. CLAIBORN:
Yeah, let me just ask one |\n| 19 | question before we do that. |\n| 20 | Q
Mr. Kwok, please confirm that the tax |\n| 21 | returns that you provided to the United States |\n| 22 | Trustee for the year 2020 and 2019 were the same as |\n| 23 | those filed with the taxing authorities? |\n| 24 | THE INTERPRETER:
The what?
Sorry, the last |\n| 25 | word. |\n\n| Case 22-50073 | Doc 404-7
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43 |\n| 1 | MS. CLAIBORN:
Authorities. |\n| 2 | Q
Yes -- |\n| 3 | THE INTERPRETER:
Could you please repeat? |\n| 4 | Sorry. |\n| 5 | Q
Mr. Kwok, can you please confirm that the |\n| 6 | tax returns that you provided to the Office of the |\n| 7 | United States Trustee for the tax years 2019 and |\n| 8 | 2020 are the same as those that you provided to the |\n| 9 | Internal Revenue Service and to the State of |\n| 10 | Connecticut and to the State of New York? |\n| 11 | A
Yes. |\n| 12 | Q
Mr. Kwok, in your 2020 tax return -- |\n| 13 | MR. BALDIGA:
I want to clarify.
As you |\n| 14 | know, there were very limited redactions as to |\n| 15 | Social Security number and maybe a couple of data |\n| 16 | points. I'm not sure if the witness knows what we |\n| 17 | did by way of that data protection, but you do. I |\n| 18 | just wanted to not leave the record ambiguous in |\n| 19 | that regard. |\n| 20 | MS. CLAIBORN:
Thank you. |\n| 21 | Q
Mr. Kwok, your 2020 tax return reports |\n| 22 | interest income only and no other source of income. |\n| 23 | Did you have any other source of income in 2020? |\n| 24 | A
No. |\n| 25 | MS. CLAIBORN:
Okay. I'm going to take a |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 45 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\nHo Wan Kwok - March 21, 2022\n\n| 1 | very short break. It is now 12:30. I would like |\n|---|-------------------------------------------------------|\n| 2 | everyone to reconvene at 12:35. I'm not going to |\n| 3 | disconnect the call.
I'm just going ask you to all |\n| 4 | put your phones on hold. |\n| 5 | We will reconvene at 12:35.
Thank you. |\n| 6 | (Off the record.) |\n| 7 | MS. CLAIBORN:
Okay.
We are back on the |\n| 8 | record after a short break. |\n| | |\n\n44\n\n9 Q Mr. Kwok, I would like to talk to you about 10 Golden Spring, New York.\n\n11 Do you currently work for Golden Spring in 12 any capacity?\n\n13 A No.\n\n14 Q When was Golden Spring New York Limited 15 formed?\n\n16 THE INTERPRETER: Sorry?\n\n17 Q When was Golden Spring New York Limited 18 formed?\n\n19 THE INTERPRETER: Sorry, I cannot get the 20 later half. Golden New York what?\n\n21 MS. CLAIBORN: I'm going to actually just 22 refer to it as Golden Spring. When I do that I'm 23 referring to Golden Spring New York.\n\n24 Q When was Golden Spring formed as a company? 25 A I don't know.\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22
83 | Entered 05/20/22 11:52:18 | Page 46 of |\n|---------------|-----------|---------------------------------------|----------------------------------------------------|--------------|\n| | | Ho Wan Kwok - March 21, 2022 | | 45 |\n| 1 | Q | | The address on the petition is 162 East 64th | |\n| 2 | Street. | Who owns that property? | | |\n| 3 | | I can ask the question again. | | |\n| 4 | | | The address for Golden Spring is listed as | |\n| 5 | | 162 East 64th Street in New York. | Who owns that | |\n| 6 | property? | | | |\n| 7 | A | I don't know. | | |\n| 8 | Q | | What is the nature of that property at 162 | |\n| 9 | | East 64th Street? | | |\n| 10 | A | | I don't know which property you're talking | |\n| 11 | about. | | | |\n| 12 | Q | | The office of Golden Spring -- | |\n| 13 | | MR. BALDIGA: | I'm not sure that was -- | |\n| 14 | | MS. CLAIBORN: | Let me just try again. | |\n| 15 | | The office of -- | | |\n| 16 | | MR. BALDIGA: | There's a translation issue. | |\n| 17 | | | Could we confer for one second because | |\n| 18 | | obviously there's a misunderstanding. | | So could Mr. |\n| 19 | | | Kwok talk to his translator because that obviously | |\n| 20 | | didn't come through. | | |\n| 21 | | MS. CLAIBORN: | Let me just -- I would prefer | |\n| 22 | | if I try again. | Let me try again, please. | |\n| 23 | Q | | The address for Golden Spring on the | |\n| 24 | | | bankruptcy petition is listed as 162 East 64th | |\n| 25 | | Street in New York. | | |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22
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46 |\n| 1 | | THE INTERPRETER:
Is it 54 or 64?
5-4 or 6- |\n| 2 | 4? | |\n| 3 | | MS. CLAIBORN:
64. |\n| 4 | | THE INTERPRETER: So maybe because of the |\n| 5 | | phone I mistook the 6 as 5 so let me correct my |\n| 6 | | mistake and reinterpret again. |\n| 7 | A | Yes, that's the address of Golden Spring. |\n| 8 | Q | Does Golden Spring own that building that's |\n| 9 | | located at that address? |\n| 10 | A | I don't know. |\n| 11 | Q | Have you ever been to that address? |\n| 12 | A | Yes. |\n| 13 | Q | What type of building is it?
What's located |\n| 14 | there? | |\n| 15 | A | It was a building. |\n| 16 | Q | Is the building a residential building or a |\n| 17 | | commercial building? |\n| 18 | A | Business building. |\n| 19 | | MS. CLAIBORN:
I'm sorry, Bin. I didn't hear |\n| 20 | | your translation. |\n| 21 | | THE INTERPRETER:
A commercial building or |\n| 22 | | business building. |\n| 23 | Q | Does anyone live at that address? |\n| 24 | A | I don't know. |\n| 25 | Q | What type of business does Golden Spring do? |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22
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47 |\n| 1 | A | It's a big family business my son works, but |\n| 2 | | I don't know specifically what categories of |\n| 3 | | business it has. |\n| 4 | Q | Mr. Kwok, when you used the term -- |\n| 5 | A | It is a family office owned by my son.
He |\n| 6 | | has other businesses, but I don't know. |\n| 7 | Q | Mr. Kwok, when you use the term family |\n| 8 | | business or family office, what do you mean by those |\n| 9 | terms? | |\n| 10 | A | It's mainly for the whole family, all the |\n| 11 | | family members.
When there is something we |\n| 12 | | (indiscernible)
and help each other. |\n| 13 | Q | Mr. Kwok, can you explain it in more detail? |\n| 14 | A | I don't know how to explain. |\n| 15 | Q | Does Golden Spring have any employees? |\n| 16 | A | Yes. |\n| 17 | Q | How many? |\n| 18 | A | I don't know. |\n| 19 | Q | Does Golden Spring own any real estate? |\n| 20 | A | I don't know. |\n| 21 | Q | Does Golden Spring own any other business? |\n| 22 | A | I don't know. |\n| 23 | Q | Does Golden Spring have any bank accounts? |\n| 24 | A | I don't know. |\n| 25 | Q | Mr. Kwok, you have previously said in |\n\n48\n\n| | Ho Wan Kwok - March 21, 2022
48 |\n|----|--------------------------------------------------------|\n| 1 | documents filed with the bankruptcy court that |\n| 2 | Golden Spring pays for you personal living expenses. |\n| 3 | Can you please explain how they do that? |\n| 4 | A
I don't know what you mean by they pay me. |\n| 5 | In what regard? |\n| 6 | Q
Mr. Kwok, you have previously told the court |\n| 7 | in your bankruptcy documents that Golden Spring pays |\n| 8 | for your clothing, your food and your housing. |\n| 9 | My question is how do they do that?
Do they |\n| 10 | give you money?
Do they pay other people directly? |\n| 11 | How does it work? |\n| 12 | A
Whenever I need any expenses for my basic |\n| 13 | living I talk to my son and he will tell his office |\n| 14 | to give to me. |\n| 15 | Q
Who are the owners of Golden Spring? |\n| 16 | MR. HARBACH:
This is David Harbach. I |\n| 17 | missed the end of that question. I talk to my son |\n| 18 | and he -- that answer.
I heard I talk to my son and |\n| 19 | he and then I lost it.
Can I please have the |\n| 20 | English again? |\n| 21 | THE INTERPRETER:
Sorry, I didn't hear the |\n| 22 | gentleman? |\n| 23 | MS. CLAIBORN:
Mr. Harbach is asking Bin if |\n| 24 | you could repeat the translation of Mr. Kwok's |\n| 25 | answer about how the money flows from Golden Spring. |\n\n| Case 22-50073 | Doc 404-7
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49 |\n| 1 | THE INTERPRETER: I'll repeat the |\n| 2 | interpretation. |\n| 3 | When I need expenses for my basic living I |\n| 4 | tell my son.
My son will tell the office to take -- |\n| 5 | Q
Mr. Kwok, who are the owners of Golden |\n| 6 | Spring? |\n| 7 | A
My son. |\n| 8 | Q
Are there any owners of Golden Spring other |\n| 9 | than your son? |\n| 10 | A
No. |\n| 11 | Q
Mr. Kwok, have you ever owned an interest in |\n| 12 | Golden Spring? |\n| 13 | A
No. |\n| 14 | Q
Who are the officers and directors of Golden |\n| 15 | Spring? |\n| 16 | MR. BALDIGA:
This is Bill Baldiga. |\n| 17 | This is something for which there are very |\n| 18 | serious physical security concerns and it's not that |\n| 19 | the debtor would refuse to answer, if he knows.
But |\n| 20 | not on a line like this where it's open to the |\n| 21 | public and who else knows.
There are -- hold on. |\n| 22 | Can I just confer with the witness because |\n| 23 | we'd like to give you as much as possible, but we |\n| 24 | don't want to cause severe security issues. |\n| 25 | So could I just have one minute to confer |\n\n| Case 22-50073 | Doc 404-7
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50 |\n| 1 | with the witness? |\n| 2 | MS. CLAIBORN:
Yes. |\n| 3 | (Pause.) |\n| 4 | MR. BALDIGA:
This is Bill Baldiga, again. |\n| 5 | The witness believes that he may know who |\n| 6 | the directors and officers are and is prepared to |\n| 7 | testify as to the best of his knowledge in that |\n| 8 | regard.
And if we could take it one question at a |\n| 9 | time we'll go from there. |\n| 10 | If you could interpret that, because I want |\n| 11 | to be sure that the witness understands what I just |\n| 12 | said as well, please. |\n| 13 | (Interpretation) |\n| 14 | BY
MS. CLAIBORN: |\n| 15 | Q
Mr. Kwok, as of today, who are the officers |\n| 16 | of Golden Spring? |\n| 17 | A
(Indiscernible) |\n| 18 | Q
I'm going to repeat that name so everyone |\n| 19 | understands what I thought I heard.
What I heard |\n| 20 | was Yan Ping, also known as Yvonne Wang.
Is that |\n| 21 | accurate? |\n| 22 | A
Yes. |\n| 23 | Q
Is Yvonne Wang the only officer of Golden |\n| 24 | Spring? |\n| 25 | A
I don't know. |\n\n| Case 22-50073 | Doc 404-7
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51 |\n| 1 | Q
As of today, who are the directors of Golden |\n| 2 | Spring? |\n| 3 | A
I don't know. |\n| 4 | Q
Mr. Kwok, have you ever been an officer or a |\n| 5 | direct or Golden Spring? |\n| 6 | A
I don't remember. |\n| 7 | Q
Mr. Kwok, who is Max Krazner? |\n| 8 | A
I don't know. I don't know. |\n| 9 | THE INTERPRETER:
Could you please repeat |\n| 10 | the name again? |\n| 11 | Q
Mr. Kwok, who is Max Krazner? |\n| 12 | (No response) |\n| 13 | Mr. Kwok, can you please answer? |\n| 14 | MR. BALDIGA:
I'm conferring with the |\n| 15 | witness for one second.
Hold on please? |\n| 16 | MS. CLAIBORN:
Mr. Baldiga, I would rather |\n| 17 | he would answer the question before you make a |\n| 18 | confer. |\n| 19 | (Pause.) |\n| 20 | MR. BALDIGA:
Thank you for that |\n| 21 | opportunity.
The witness could answer. |\n| 22 | A
He has to double check with you because I |\n| 23 | cannot read and cannot remember English names well. |\n| 24 | So just the name, you said Max.
If it's the name |\n| 25 | Max only I know Max.
But if you add another name to |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22
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83 |\n|---------------|--------------|-----------------------------------------------------------------|\n| | | Ho Wan Kwok - March 21, 2022
52 |\n| 1 | | it, I'm not sure. I don't know. |\n| 2 | Q | Do you know a Max with respect to Golden |\n| 3 | Spring? | |\n| 4 | A | Yes. I know. |\n| 5 | Q | And what is Max's role with Golden Spring? |\n| 6 | A | I don't know. |\n| 7 | Q | Well, how do you know Max? |\n| 8 | A | I don't remember. |\n| 9 | Q | Do you know more than one person by the name |\n| 10 | of Max? | |\n| 11 | A | For me English name is very complicated. |\n| 12 | | Like I can't remember the last name of my lawyer. If |\n| 13 | | you add something else to Max, I don't know. |\n| 14 | Q | Mr. Kwok, the name Max Krazner is listed as |\n| 15 | | the person to whom the mail for Golden Spring is |\n| 16 | directed to. | Do you know why that is? |\n| 17 | | THE INTERPRETER:
Sorry? |\n| 18 | Q | Do you know why that is? |\n| 19 | A | I only remember there is a Max at Golden |\n| 20 | | Spring. I only know this one thing. |\n| 21 | Q | And what is Max's job at Golden Spring? |\n| 22 | A | I'm not sure what role.
I (indiscernible) |\n| 23 | | know he is in charge of finance, but I'm not sure. |\n| 24 | Q | What does he do for Golden Spring with |\n| 25 | | respect to finances? |\n\n| Case 22-50073 | Doc 404-7
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53 |\n| 1 | A
I was not involved in the management so I |\n| 2 | don't know. |\n| 3 | Q
If Golden Spring gives you money, does it |\n| 4 | come through Max Krazner's efforts?
Does he help |\n| 5 | make that happen? |\n| 6 | A
I don't know.
He didn't give me money in |\n| 7 | person. |\n| 8 | Q
Mr. Kwok, when you get money from Golden |\n| 9 | Spring how do you get money?
Does it come in the |\n| 10 | form of cash or something else? |\n| 11 | A
From my son and (indiscernible). |\n| 12 | MS. CLAIBORN:
I'm sorry, Bin.
I didn't |\n| 13 | understand your translation.
Can you try that |\n| 14 | again? |\n| 15 | THE INTERPRETER:
He said from my son and |\n| 16 | (indiscernible). |\n| 17 | Q
My question was how do you get money from |\n| 18 | your son?
Does it come in the form of cash or some |\n| 19 | other form? |\n| 20 | A
I don't understand what you mean by how, the |\n| 21 | word how.
I never get money directly from them. |\n| 22 | Q
If you don't get money directly from your |\n| 23 | son, how do you get the money from your son?
Where |\n| 24 | does it go? |\n| 25 | A
I don't use cash and I don't use credit |\n\nHo Wan Kwok - March 21, 2022\n\n54\n\n| 1 | cards.
My son and (indiscernible)
Wan they just |\n|----|---------------------------------------------------------|\n| 2 | pay my expenses for me.
It's impossible for me to |\n| 3 | get any cash from them. And also I don't have bank |\n| 4 | account.
Any bank accounts. |\n| 5 | Q
Mr. Kwok, do you have access to a credit |\n| 6 | card that was taken out by Golden Spring? |\n| 7 | MR. BALDIGA:
This is Bill Baldiga. I'm |\n| 8 | sorry.
I think there was a translation issue with |\n| 9 | the prior question.
Could you give us a minute to |\n| 10 | be sure that the witness understood the question |\n| 11 | correctly?
Hold on for one second.
We're going to |\n| 12 | put it on mute. |\n| 13 | (Pause.) |\n| 14 | MR. BALDIGA:
The witness would like to |\n| 15 | clarify. I think it came through, but we're not |\n| 16 | sure, that Golden Spring does not give him cash, but |\n| 17 | simply pays certain bills for his living expenses. |\n| 18 | If that's what came through the translation, great. |\n| 19 | If not, we clarify accordingly. |\n| 20 | Q
Mr. Kwok, do you have access to a credit |\n| 21 | card or a debit card provided to you by or through |\n| 22 | Golden Spring? |\n| 23 | A
No. |\n| 24 | Q
Mr. Kwok, are you obligated to pay Golden |\n| 25 | Spring back for the monies that it pays on your |\n\n| Case 22-50073 | Doc 404-7
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55 |\n| 1 | behalf for your living expenses? |\n| 2 | A
No.
No need. |\n| 3 | MS. CLAIBORN:
At this time I'd like to open |\n| 4 | the meeting to creditors, given that we have a |\n| 5 | limited amount of time for today. I am not done with |\n| 6 | all my questions. |\n| 7 | We will need to reconvene on another day, |\n| 8 | but for purposes of today's examination I'm now |\n| 9 | going to open it up to creditors who may wish to |\n| 10 | examine. |\n| 11 | I would ask that you identify yourself when |\n| 12 | you speak and to be mindful of the need for |\n| 13 | interpretation. |\n| 14 | MR. BALDIGA:
Just to clarify one thing for |\n| 15 | the record.
You asked previously -- you referred to |\n| 16 | the petition and asked whether anyone lived at 162 |\n| 17 | East 64th Street. |\n| 18 | And as we told you informally when we filed |\n| 19 | the petition there was great concern over the |\n| 20 | debtor's physical security and so he used that |\n| 21 | address, but has since, obviously, corrected the |\n| 22 | record that he lives in the Greenwich house that you |\n| 23 | asked about earlier today. |\n| 24 | And so I just didn't want the record to be |\n| 25 | confusing in that regard.
Thank you. |\n\n## Case 22-50073 Doc 404-7 Filed 05/20/22 Entered 05/20/22 11:52:18 Page 57 of\n\n83\n\n Ho Wan Kwok - March 21, 2022\n\n| 1 | MS. CLAIBORN:
Are there any creditors who |\n|----|--------------------------------------------------------|\n| 2 | wish to inquire or examine of the debtor? |\n| 3 | MR. HARBACH:
Yes.
This is David Harbach |\n| 4 | for PACS.
We do have some questions. We do have |\n| 5 | some questions.
We can start asking the questions |\n| 6 | now or if there are others who would like to ask |\n| 7 | questions that's fine.
However you want to proceed. |\n| 8 | But we obviously will not finish before 2 o'clock |\n| 9 | either. |\n| 10 | THE INTERPRETER:
I cannot hear you clearly. |\n| 11 | MR. HARBACH:
This is David Harbach for PACS |\n| 12 | and I was just saying that we do have some questions |\n| 13 | and we are happy to proceed and ask them or if the |\n| 14 | trustee would like. we can proceed with others |\n| 15 | asking questions but we will certainly not finish |\n| 16 | before 2 o'clock either. |\n| 17 | MR. BALDIGA:
Could that be translated |\n| 18 | please? |\n| 19 | THE INTERPRETER:
I was saying I could not |\n| 20 | get him completely. |\n| 21 | MS. CLAIBORN:
Mr. Harbach, do you have the |\n| 22 | ability to pick up a hand held and speak into a hand |\n| 23 | held device, as opposed to a speaker phone? |\n| 24 | MR. HARBACH:
Not at this moment, but let me |\n| 25 | move to see if this is any better.
Can you hear me |\n\n| Case 22-50073 | Doc 404-7
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57 |\n| 1 | a little better now? |\n| 2 | THE INTERPRETER:
Not really.
No, sorry. |\n| 3 | MR. HARBACH:
Not really.
Well, I'll tell |\n| 4 | you what.
If you give me -- take a moment, I can |\n| 5 | try dialing in with a phone.
Just give me a second, |\n| 6 | okay? |\n| 7 | MS. CLAIBORN:
Yes. |\n| 8 | MR. BALDIGA:
Bin, could you translate the |\n| 9 | dialogue for Mr. Kwok, please, so he knows that. |\n| 10 | (Interpreter translates) |\n| 11 | MR. HARBACH:
Hello? |\n| 12 | MS. CLAIBORN:
Hello.
This is Holley |\n| 13 | Claiborn. |\n| 14 | MR. HARBACH:
This is David Harbach and I |\n| 15 | just wanted to know if you could hear me better. |\n| 16 | MS. CLAIBORN:
Much better.
Bin, can you |\n| 17 | hear Mr. Harbach? |\n| 18 | THE INTERPRETER:
Yes, I can hear him now. |\n| 19 | Thank you. |\n| 20 | MS. CLAIBORN:
Go ahead, Mr. Harbach. |\n| 21 | MR. HARBACH:
I'll repeat what I said once |\n| 22 | more so that the interpreter can interpret it. |\n| 23 | I'm David Harbach and I was just saying that |\n| 24 | PACS does have some questions we would like to ask, |\n| 25 | but we certainly will not finish by 2 o'clock and so |\n\n Ho Wan Kwok - March 21, 2022 83\n\n| 1 | if Ms. Claiborn would like to proceed with giving |\n|----|-----------------------------------------------------|\n| 2 | other creditors an opportunity to ask questions |\n| 3 | today, it's entirely up to her or we can start now. |\n| 4 | MR. BALDIGA:
And this is Bill Baldiga. We |\n| 5 | extended our own translator until 2 o'clock so we |\n| 6 | certainly encourage whoever wants to ask questions |\n| 7 | to use the time. |\n| 8 | MR. WOLMAN:
This is Jay Wolman. I'm happy |\n| 9 | to ask some questions now. |\n| 10 | THE INTERPRETER:
Sorry, I didn't get your |\n| 11 | name. |\n| 12 | MR. WOLMAN: Jay Wolman, and I represent |\n| 13 | Logan Chang. |\n| 14 | EXAMINATION BY MR. WOLMAN: |\n| 15 | Q
Good afternoon, Mr. Kwok. |\n| 16 | Do you remember that I took your deposition |\n| 17 | about a year ago? |\n| 18 | A
I have too many -- |\n| 19 | THE INTERPRETER:
Someone's always talking |\n| 20 | in the background. |\n| 21 | A
I have too many depositions.
I don't |\n| 22 | remember specifically. |\n| 23 | Q
That's all right. I asked you a number of |\n| 24 | questions and you invoked your rights under the |\n| 25 | Fifth Amendment of the U.S. Constitution.
Do you |\n\n| Case 22-50073 | Doc 404-7
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59 |\n| 1 | understand that? |\n| 2 | THE INTERPRETER:
You and your wife what? |\n| 3 | Sorry. |\n| 4 | Q
You invoked your right under the Fifth |\n| 5 | Amendment of the U.S. Constitution.
Do you remember |\n| 6 | that? |\n| 7 | MR. BALDIGA:
We have a translation issue. |\n| 8 | Hold on for one second, please. |\n| 9 | (Pause.) |\n| 10 | MR. BALDIGA:
I think -- our interpreter is |\n| 11 | hearing this translation.
The question as we |\n| 12 | understand is do you remember having invoked the |\n| 13 | Fifth Amendment privilege at a prior deposition. |\n| 14 | That's what we are hearing.
Could that be |\n| 15 | interpreter for Mr. Kwok in that way please? |\n| 16 | THE INTERPRETER:
Sorry, I can I hear the |\n| 17 | question again. |\n| 18 | MR. WOLMAN:
Sure. |\n| 19 | Q
Do you remember at a prior deposition |\n| 20 | invoking the Fifth Amendment of the U.S. |\n| 21 | Constitution? |\n| 22 | THE INTERPRETER:
Sorry, I did not hear you |\n| 23 | clearly. |\n| 24 | Q
Do you remember at a prior deposition |\n| 25 | invoking the Fifth Amendment of the U.S. |\n\n Ho Wan Kwok - March 21, 2022 60 1 Constitution? 2 THE INTERPRETER: At a prior what? Sorry. 3 MR. WOLMAN: Deposition. D-E-P-O-S-I-T-I-O-4 N. 5 THE INTERPRETER: Deposition. Sorry, just 6 one sec. 7 (Pause.) 8 THE INTERPRETER: Okay. In the prior 9 deposition what? 10 Q Do you remember invoking your Fifth 11 Amendment rights? 12 THE INTERPRETER: Invoking what? 13 MR. WOLMAN: Can everybody else hear me or 14 is it just the interpreter? 15 MS. CLAIBORN: This is Holley. I can hear 16 you. 17 MR. HARBACH: This is David Harbach. We can 18 hear you fine. 19 MR. BALDIGA: The debtor can hear you. It's 20 not a volume issue. 21 MR. WOLMAN: Is it a diction issue? I can 22 try to -- Case 22-50073 Doc 404-7 Filed 05/20/22 Entered 05/20/22 11:52:18 Page 61 of 83\n\n23 THE INTERPRETER: The interpreter just 24 didn't get the word. (Indiscernible) rewording. 25 MR. WOLMAN: I cannot reword that. I need\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 62 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\n| | Ho Wan Kwok - March 21, 2022
61 |\n|----|------------------------------------------------------|\n| 1 | you to hear the words in English and translate them, |\n| 2 | ma'am. |\n| 3 | THE INTERPRETER:
Okay.
Could you please |\n| 4 | speak slowly? |\n| 5 | Q
Do you remember at a prior deposition |\n| 6 | invoking your rights under the Fifth, number five |\n| 7 | that is -- Fifth Amendment, ordinal number -- of the |\n| 8 | U.S. Constitution? |\n| 9 | THE INTERPRETER:
Invoke or evoke? |\n| 10 | MR. WOLMAN:
Invoke, I-N-V-O-K-E. |\n| 11 | Okay, we still have an issue. |\n| 12 | UNIDENTIFIED:
Hold on. |\n| 13 | UNIDENTIFIED:
Did someone just drop out? |\n| 14 | MS. CLAIBORN:
Bin, are you there?
This is |\n| 15 | Holley. |\n| 16 | MR. WOLMAN:
Bin? |\n| 17 | MS. CLAIBORN:
Bin, are you there? |\n| 18 | THE INTERPRETER:
Hello. |\n| 19 | MS. CLAIBORN:
Bin, this is Holley Claiborn. |\n| 20 | THE INTERPRETER:
Okay. I'm back. |\n| 21 | MS. CLAIBORN:
Okay. |\n| 22 | THE INTERPRETER:
I don't know what |\n| 23 | happened. |\n| 24 | MS. CLAIBORN:
Go ahead. |\n| 25 | MR. BALDIGA:
Is the interpreter -- we're |\n\n| Case 22-50073 | Doc 404-7
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62 |\n| 1 | not sure what's going on.
Is the interpreter with |\n| 2 | us or not? |\n| 3 | THE INTERPRETER:
Yes, the interpreter is |\n| 4 | here now. |\n| 5 | MR. BALDIGA:
Okay.
Thank you. |\n| 6 | My client just said something and I don't |\n| 7 | know what he said and I don't know whether you were |\n| 8 | on for what he said.
If you were, I'd like to know |\n| 9 | -- I'd like you to interpret it.
If not, could you |\n| 10 | let us confer for a second so we could try to figure |\n| 11 | that out, because there was a lot of confusion. |\n| 12 | MR. WOLMAN:
Bill, can you just ask your |\n| 13 | client to repeat what he just said? |\n| 14 | MR. BALDIGA:
No -- |\n| 15 | THE INTERPRETER:
The interpreter would like |\n| 16 | him to repeat what he said because just now all of a |\n| 17 | sudden I'm not (indiscernible)
all the voices |\n| 18 | sometimes. |\n| 19 | I'm asking the gentleman to repeat what he |\n| 20 | said just now. |\n| 21 | MR. KWOK: Just now in your question you |\n| 22 | mentioned that -- you asked me whether my wife used |\n| 23 | something under the law or under the Constitution. |\n| 24 | I don't remember that. |\n| 25 | MR. WOLMAN: I said nothing about his wife. |\n\n| Case 22-50073 | Doc 404-7
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63 |\n| 1 | MR. KWOK:
So did you say just now my wife |\n| 2 | use any kind of law or what? |\n| 3 | MR. WOLMAN:
No, that was nothing of the |\n| 4 | sort. |\n| 5 | MR. BALDIGA:
Could I suggest, Mr. Wolman, |\n| 6 | maybe you could just go right to whatever you want |\n| 7 | to ask him instead of what happened a year ago |\n| 8 | because this is not getting anywhere. |\n| 9 | MR. WOLMAN:
Well, I'm going to re-ask him |\n| 10 | every question relative to finances where he invoked |\n| 11 | the Fifth and I wanted to make sure he had that in |\n| 12 | his mind as he answers here today. |\n| 13 | MR. BALDIGA:
Is there a question? |\n| 14 | MR. WOLMAN:
I want to make sure you're |\n| 15 | aware of what I'm about to do. |\n| 16 | At this point, I have no idea, but I am |\n| 17 | representing to you that is exactly what I'm doing. |\n| 18 | So I want to make sure your client is appropriately |\n| 19 | advised. |\n| 20 | BY MR. WOLMAN: |\n| 21 | Q
So a year ago -- this is a lengthy one, Bin, |\n| 22 | so please just write it down, or do what you need to |\n| 23 | do. Let me finish and then translate.
Do not do |\n| 24 | that piecemeal. |\n| 25 | THE INTERPRETER:
Okay. |\n\n| Case 22-50073 | Doc 404-7
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64 |\n| 1 | MR. BALDIGA:
I -- |\n| 2 | MR. WOLMAN:
Hold on. I want the translation |\n| 3 | of that and we'll take this in small pieces.
So |\n| 4 | Bin, please translate that for the witness because |\n| 5 | he has to hear everything. |\n| 6 | (Translation.) |\n| 7 | THE INTERPRETER:
Yes. |\n| 8 | MR. WOLMAN:
Thank you. |\n| 9 | BY MR. WOLMAN: |\n| 10 | Q
A year ago I asked you are you employed. |\n| 11 | You answered I have always been -- |\n| 12 | THE INTERPRETER:
I asked you what? Sorry. |\n| 13 | Q
Are you employed? |\n| 14 | There's a lot of background noise.
Can we |\n| 15 | knock that off, please. |\n| 16 | A year ago I asked you are you employed? |\n| 17 | THE INTERPRETER:
You employed? |\n| 18 | Q
A year ago I asked you are you employed? |\n| 19 | Your answer was I have always been a consultant for |\n| 20 | -- |\n| 21 | THE INTERPRETER:
Sorry.
A year ago I asked |\n| 22 | you are you employed?
The answer is what? |\n| 23 | Q
I have always been the consultant for a lot |\n| 24 | of companies -- |\n| 25 | THE INTERPRETER:
I'm sorry -- |\n\n Ho Wan Kwok - March 21, 2022 83\n\n65\n\n| 1 | Q
And my current employment is the -- I am in |\n|----|--------------------------------------------------------|\n| 2 | the broadcasting and to take down the Chinese |\n| 3 | Communist Party.
It is a broadcasting revolution. I |\n| 4 | then asked you how much do you get paid for that. |\n| 5 | I'm re-asking that question now.
How much |\n| 6 | do you get paid for that? |\n| 7 | THE INTERPRETER:
So I have to do it from |\n| 8 | the beginning because I didn't get the words when |\n| 9 | you say a year ago I asked you whether -- are you |\n| 10 | employed?
Your answer is I didn't get the word |\n| 11 | after is. |\n| 12 | Q
Your answer was I always been the consultant |\n| 13 | for a lot of companies and my current employment is |\n| 14 | the -- he paused.
I am in the broadcasting -- |\n| 15 | THE INTERPRETER:
Is what?
Sorry? |\n| 16 | Q
-- and to take down -- |\n| 17 | THE INTERPRETER:
Sorry. |\n| 18 | Q
I am in the broadcasting and to take down |\n| 19 | the Chinese Communist Party.
It is a broadcasting |\n| 20 | revolution.
I then asked you how much do you get -- |\n| 21 | THE INTERPRETER:
Excuse me. I'm not able to |\n| 22 | -- |\n| 23 | MR. WOLMAN:
Excuse me. I'm not done.
Why |\n| 24 | not? |\n| 25 | THE INTERPRETER:
I tried to clarify -- |\n\n| Case 22-50073 | Doc 404-7
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66 |\n| 1 | MR. WOLMAN:
Why not? |\n| 2 | THE INTERPRETER:
-- the words that I didn't |\n| 3 | get.
Yes, I know it's simple but it's too long.
I |\n| 4 | (indiscernible)
such a long time to do the |\n| 5 | interpretation. I'm highly concentrating. I have a |\n| 6 | human brain. |\n| 7 | MR. WOLMAN:
I'm used to translators writing |\n| 8 | things down as they go. |\n| 9 | THE INTERPRETER:
Sorry about that. |\n| 10 | Let me interpret what I got and then I will |\n| 11 | ask you the rest.
Is that okay? |\n| 12 | MR. WOLMAN:
Yes. |\n| 13 | THE INTERPRETER:
Okay. |\n| 14 | (Translation) |\n| 15 | THE INTERPRETER:
Okay.
I -- |\n| 16 | Q
I then asked you how much do you get paid |\n| 17 | for that and I am asking you now again, because you |\n| 18 | invoked the Fifth, how much do you get paid for |\n| 19 | that? |\n| 20 | (Pause.) |\n| 21 | MR. BALDIGA:
Okay. The witness is |\n| 22 | struggling to -- well, is the question are you |\n| 23 | getting paid for that?
And you can answer that. |\n| 24 | MR. WOLMAN:
No.
I am literally asking him |\n| 25 | how much do you get paid for that. He took the |\n\n| Case 22-50073 | Doc 404-7
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67 |\n| 1 | Fifth. I'm asking it now again. |\n| 2 | Q
How much do you get paid for that? |\n| 3 | A
No money at all. |\n| 4 | Q
A year ago I asked you what is Golden Spring |\n| 5 | New York.
You answered it's a company. I then asked |\n| 6 | you and what is your -- I then asked you and what is |\n| 7 | your relationship to that company and so I'm asking |\n| 8 | that question again.
What is your relationship to |\n| 9 | that company? |\n| 10 | A
I don't know what you mean by relationship. |\n| 11 | Q
If you didn't know what I meant by that |\n| 12 | question, why did you invoke the Fifth last year? |\n| 13 | MR. BALDIGA:
Objection.
I'm not going to |\n| 14 | allow the witness to describe the legal advice a |\n| 15 | year ago as to the Fifth Amendment. |\n| 16 | He is prepared to answer whatever questions |\n| 17 | you may have. You are confusing the witness a bit by |\n| 18 | in each question having three things, some reference |\n| 19 | to the Fifth Amendment, some conversation from a |\n| 20 | year ago and a question as to now. |\n| 21 | But if you were to ask a more simple |\n| 22 | question, I think this would go much more |\n| 23 | productively.
That's your choice. |\n| 24 | MR. WOLMAN:
No.
Your client is an |\n| 25 | intelligent person who is a big businessman, who is |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 69 of |\n|---------------|-----------|----------------|---------------------------|------------|\n| | | | | |\n\n Ho Wan Kwok - March 21, 2022 83\n\n68\n\n| 1 | a sophisticated person. I trust he can handle these |\n|----|--------------------------------------------------------|\n| 2 | simple questions. |\n| 3 | MR. BALDIGA:
Proceed as you'd like. |\n| 4 | (Translation interrupted) |\n| 5 | Q
Last year I asked you -- |\n| 6 | MR. BALDIGA:
Wait.
Hold on.
Mr. Wolman, |\n| 7 | there's a translation that needs to be done.
Please |\n| 8 | hold on.
The witness needs to understand what's |\n| 9 | being said. |\n| 10 | (Translation) |\n| 11 | THE INTERPRETER:
Okay.
Go ahead. |\n| 12 | Q
What is your relationship to Golden Spring? |\n| 13 | A
I don't understand what you mean by your |\n| 14 | question?
I don't know how to answer your question. |\n| 15 | Q
Do you know what the word relationship |\n| 16 | means? |\n| 17 | A
Relationship means love of things in China. |\n| 18 | It could be between husband and wife. It could be |\n| 19 | between a government relationship, a financial |\n| 20 | relationship, money and it could be a lot of things. |\n| 21 | So I don't know which one you mean?
Is it a |\n| 22 | man/woman relationship or a money relationship or |\n| 23 | what? |\n| 24 | Q
Any relationship?
What is it? What is your |\n| 25 | (indiscernible)
-- |\n\n| Case 22-50073 | Doc 404-7
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69 |\n| 1 | THE INTERPRETER:
Sorry?
What was your last |\n| 2 | sentence again, because there was talking. |\n| 3 | Q
Any relationship, what is yours to Golden |\n| 4 | Spring? |\n| 5 | THE INTERPRETER:
Let me do the |\n| 6 | interpretation first. |\n| 7 | A
Now the relationship is between -- is he |\n| 8 | lends me money. I owe money to him.
He helps me. |\n| 9 | Q
And why does he do this? |\n| 10 | A
Because I was once a member of the Guo (ph) |\n| 11 | family. |\n| 12 | MR. HARBACH:
This is David Harbach.
Could |\n| 13 | you please repeat that English answer? |\n| 14 | THE INTERPRETER:
Because I was once a |\n| 15 | member of Guo family. |\n| 16 | Q
Does Golden Spring pay the expenses of any |\n| 17 | other member of the Guo family? |\n| 18 | A
Yes. |\n| 19 | Q
Which other members of the Guo family? |\n| 20 | A
I don't know. |\n| 21 | Q
A year ago I asked you why does Golden |\n| 22 | Spring pay Mr. Podhaskie, P-O-D-H-A-S-K-I-E, for |\n| 23 | services rendered to you in your individual |\n| 24 | capacity. I'm asking that again now.
Why does |\n| 25 | Golden Spring pay Mr. Podhaskie for services |\n\nCase 22-50073 Doc 404-7 Filed 05/20/22 Entered 05/20/22 11:52:18 Page 71 of\n\n| | Ho Wan Kwok - March 21, 2022
70 |\n|----|------------------------------------------------------|\n| 1 | rendered to you in your individual capacity? |\n| 2 | MR. BALDIGA:
This is Bill Baldiga. I |\n| 3 | understand that Mr. Podhaskie may be a lawyer. I |\n| 4 | just need to confer with the client to make sure he |\n| 5 | doesn't disclose the substance of legal advice. I'll |\n| 6 | take one second to do that. |\n| 7 | MR. WOLMAN:
The question didn't indicate |\n| 8 | any answer of that sort. |\n| 9 | (Pause.) |\n| 10 | MR. BALDIGA:
I'm sorry. The witness could |\n| 11 | answer the question. |\n| 12 | MR. KWOK:
I don't know. |\n| 13 | Q
Have you ever asked anyone why they pay for |\n| 14 | him to advise you? |\n| 15 | A
I don't remember. |\n| 16 | Q
I asked you last year why did Golden Spring |\n| 17 | New York pay that judgment on your behalf, and I was |\n| 18 | referring to the one my client, Mr. Cheng, held |\n| 19 | against you. |\n| 20 | I'm asking you again why did Golden Spring |\n| 21 | New York pay that judgment on your behalf? |\n| 22 | A
It was money lended. |\n| 23 | Q
Why did Golden Spring loan you that money? |\n| 24 | A
I don't have any thing so I borrowed from |\n| 25 | them. |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22
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71 |\n| 1 | Q | Where did Golden Spring get the money from? |\n| 2 | A | I don't know. |\n| 3 | Q | Where does Golden Spring get any money from? |\n| 4 | A | I don't know. |\n| 5 | Q | Your son owns Golden Spring, correct? |\n| 6 | A | Yes. |\n| 7 | Q | Does your son owe you any money? |\n| 8 | A | No. |\n| 9 | Q | How did your son get the money that funds |\n| 10 | Golden Spring? | |\n| 11 | A | I don't know. |\n| 12 | Q | Did you ever provide your son with any seed |\n| 13 | capital? | |\n| 14 | A | No. |\n| 15 | Q | Have you ever invested in any of your son's |\n| 16 | businesses? | |\n| 17 | A | No. |\n| 18 | Q | When did Connecticut become your residence? |\n| 19 | A | End of February or early March of 2020. |\n| 20 | Q | Okay.
And you're sure about that here? |\n| 21 | A | Yes. |\n| 22 | Q | And was that your primary residence since |\n| 23 | | February, 2020 or March, 2020? |\n| 24 | A | Yes. |\n| 25 | Q | A year ago I asked you if you owned any |\n\n| Case 22-50073 | Doc 404-7
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72 |\n| 1 | interest in Golden Spring New York. I am asking you |\n| 2 | that again.
Do you own any interest in Golden |\n| 3 | Spring New York? |\n| 4 | A
No. |\n| 5 | Q
A year ago I asked you are you an officer of |\n| 6 | Golden Spring New York Limited. I'm asking you |\n| 7 | again.
Are you an officer of Golden Spring New York |\n| 8 | Limited? |\n| 9 | A
No. |\n| 10 | Q
A year ago I asked you why would Golden |\n| 11 | Spring pay Attorney Aaron, meaning Aaron Mitchell, |\n| 12 | on your behalf. |\n| 13 | I'm asking you again, why would Golden |\n| 14 | Spring pay Attorney Aaron Mitchell on your behalf? |\n| 15 | THE INTERPRETER:
He wants me to repeat the |\n| 16 | interpretation.
I'll do that for him. |\n| 17 | A
A loan.
A loan or borrowed money. |\n| 18 | Q
Why did they make you that loan? |\n| 19 | A
I have been borrowing from them all the time |\n| 20 | because I was a member of the family. |\n| 21 | Q
Did you ever have any of your loans from |\n| 22 | Golden Spring put in writing? |\n| 23 | A
Some have, some no. |\n| 24 | Q
Okay.
Which ones have been put in writing? |\n| 25 | A
I don't remember. |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22
83 | Entered 05/20/22 11:52:18 | Page 74 of |\n|---------------|---------------------|----------------------------------|-----------------------------------------------------|------------|\n| | | Ho Wan Kwok - March 21, 2022 | | 73 |\n| 1 | Q | | How many loans have you had from Golden | |\n| 2 | Spring? | | | |\n| 3 | A | I don't remember. | | |\n| 4 | Q | | Were any of the loans that were put in | |\n| 5 | writing in English? | | | |\n| 6 | A | I don't remember. | | |\n| 7 | Q | | Were any of them in Chinese? | |\n| 8 | A | I don't remember. | | |\n| 9 | Q | | Did you ever pledge any security interest in | |\n| 10 | | exchange for any of these loans? | | |\n| 11 | A | (Indiscernible) | but I don't remember | |\n| 12 | (indiscernible). | | | |\n| 13 | | MR. BALDIGA: | Could you please repeat the | |\n| 14 | answer in English? | | | |\n| 15 | | THE INTERPRETER: | He said (indiscernible) | |\n| 16 | | yes, but I don't remember. | | |\n| 17 | Q | | If you don't remember how much -- if you | |\n| 18 | | | don't remember how many loans you took out, how are | |\n| 19 | | | you able to identify how much they -- you owe them | |\n| 20 | | on your bankruptcy schedules? | | |\n| 21 | A | I didn't quite get you. | | |\n| 22 | Q | | If you don't know how many times you took | |\n| 23 | | | out loans from Golden Spring, not all of which were | |\n| 24 | | | in writing, how do you know how much you owe them? | |\n| 25 | A | | My lawyer and the lawyer of Golden Spring | |\n\nCase 22-50073 Doc 404-7 Filed 05/20/22 Entered 05/20/22 11:52:18 Page 75 of\n\n83\n\n| 74 | |\n|----|--|\n| | |\n\n| | Ho Wan Kwok - March 21, 2022
74 |\n|----|------------------------------------------------------|\n| 1 | they communicate with each other.
Tells me the |\n| 2 | amount they can define is 21 million. |\n| 3 | Q
So Golden Spring's lawyers helped prepare |\n| 4 | your bankruptcy petition?
Is that correct? |\n| 5 | MR. BALDIGA:
I'm sorry to interrupt. |\n| 6 | (Indiscernible)
two things. |\n| 7 | A
No. |\n| 8 | Q
So how did the information get from Golden |\n| 9 | Spring to your bankruptcy petition? |\n| 10 | MR. BALDIGA:
Objection to the question. |\n| 11 | THE INTERPRETER:
Sorry? |\n| 12 | MR. BALDIGA:
I object to the question. |\n| 13 | MR. WOLMAN: I'm just trying to figure out |\n| 14 | how this information he doesn't know wound up in his |\n| 15 | bankruptcy petition? |\n| 16 | MR. BALDIGA:
I think you heard the answer |\n| 17 | that his lawyer and Golden Spring's lawyer discussed |\n| 18 | it.
Do you have another question? |\n| 19 | Q
Yes.
How did you know that number was |\n| 20 | right? |\n| 21 | MR. BALDIGA:
Okay.
Let the interpreter go |\n| 22 | first and then ask another question, please. |\n| 23 | THE INTERPRETER:
Okay.
Go ahead. |\n| 24 | Q
How did you know that number was right? |\n| 25 | THE INTERPRETER:
Sorry?
Number of what? |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 76 of |\n|---------------|-----------|----------------|---------------------------|------------|\n|---------------|-----------|----------------|---------------------------|------------|\n\n| | Ho Wan Kwok - March 21, 2022
75 |\n|----|------------------------------------------------------|\n| 1 | Q
The number that was put into your bankruptcy |\n| 2 | petition for what you purportedly owe to Golden |\n| 3 | Spring, how did you know that was right? |\n| 4 | A
I believe the professionalism of my lawyers. |\n| 5 | They will review and check all the figures. |\n| 6 | MS. CLAIBORN:
This is Holley -- |\n| 7 | Q
Do you know the documents that were |\n| 8 | reviewed? |\n| 9 | MS. CLAIBORN:
I apologize for interrupting. |\n| 10 | MR. BALDIGA:
It's now 2 o'clock. |\n| 11 | MS. CLAIBORN:
I apologize for interrupting. |\n| 12 | It's Holley Claiborn. |\n| 13 | MR. WOLMAN:
Yes, thank you for |\n| 14 | filibustering to use up the time.
Appreciate it. |\n| 15 | MR. BALDIGA:
I'm sorry. Who was that |\n| 16 | addressed to?
That's quite an inappropriate |\n| 17 | comment. |\n| 18 | MR. WOLMAN:
You. That was me addressing |\n| 19 | that to you. |\n| 20 | MS. CLAIBORN:
I'd like to talk about -- |\n| 21 | MR. BALDIGA:
Okay -- |\n| 22 | MS. CLAIBORN:
-- the next date.
I was |\n| 23 | going to suggest that we reconvene April 4th at |\n| 24 | 10:00 a.m. in person at the U.S. Trustee's Office in |\n| 25 | New Haven. |\n\n| Case 22-50073 | Doc 404-7
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76 |\n| 1 | Mr. BALDIGA:
We'll look at schedules. I can |\n| 2 | start to do that if you give me a second. |\n| 3 | MS. CLAIBORN:
Bin, could you please |\n| 4 | translate that? |\n| 5 | THE INTERPRETER:
I will double check with |\n| 6 | you whether you still need me on the line for a |\n| 7 | second or you want me to log off? |\n| 8 | MS. CLAIBORN:
If you can continue on just |\n| 9 | for a second.
We need to pick a new date, so I need |\n| 10 | you to translate that so the debtor understands. |\n| 11 | THE INTERPRETER:
Okay. |\n| 12 | MR. BALDIGA:
I'm sorry.
Was the request -- |\n| 13 | I'm sorry.
Was the request -- I'm just trying to |\n| 14 | make sure I heard it -- April 4 at 10 o'clock in |\n| 15 | Bridgeport? |\n| 16 | MS. CLAIBORN:
April 4, 10 o'clock in New |\n| 17 | Haven at the U.S. Trustee's Office. |\n| 18 | MR. BALDIGA:
Okay.
We'll be back to you |\n| 19 | very quick on that. |\n| 20 | MS. CLAIBORN:
I actually need an answer on |\n| 21 | that right now because we need to be able to notify |\n| 22 | creditors and I want everyone to know before we |\n| 23 | conclude today. |\n| 24 | MR. BALDIGA:
Okay. I'll put you on hold. |\n| 25 | MR. HARBACH:
Ms. Claiborn, this is David |\n\n| Case 22-50073 | Doc 404-7
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77 |\n| 1 | Harbach.
I'm afraid that that day will not work for |\n| 2 | us? |\n| 3 | MS. CLAIBORN:
Mr. Harbach, is that you? |\n| 4 | MR. HARBACH:
Yes, ma'am.
And I was just |\n| 5 | about to say that I can do Wednesday, the 6th, or |\n| 6 | any day after that.
But I cannot do the 4th or the |\n| 7 | 5th. |\n| 8 | MS. CLAIBORN:
How about Friday, April 8th? |\n| 9 | MR. HARBACH:
I can do that.
This is David. |\n| 10 | I can do that. |\n| 11 | MR. WOLMAN:
This is Jay Wolman.
I can do |\n| 12 | that. |\n| 13 | MS. CLAIBORN:
Attorney Baldiga, can you |\n| 14 | check on April 8th, please? |\n| 15 | (Pause.) |\n| 16 | MR. HARBACH:
Holley, this is Dave Harbach |\n| 17 | again.
Just anticipating that they're coming back |\n| 18 | (indiscernible).
I could also do it (indiscernible) |\n| 19 | for whatever it's worth.
I could also do it on the |\n| 20 | 28th, 29 or 30 of March as well, if that's better. |\n| 21 | MR. BALDIGA:
This is Bill Baldiga.
The 7th |\n| 22 | and 8th are Buddhist holidays so for religious |\n| 23 | reasons Mr. Kwok can't do it those days.
We'll |\n| 24 | clear the 4th. I'm sure there are some |\n| 25 | (indiscernible). I'm wondering who could make it. |\n\n| Case 22-50073 | Doc 404-7 | Filed 05/20/22 | Entered 05/20/22 11:52:18 | Page 79 of |\n|---------------|-----------|----------------|---------------------------|------------|\n| | | | | |\n\n Ho Wan Kwok - March 21, 2022 83\n\n| | Ho Wan Kwok - March 21, 2022
78 |\n|----|------------------------------------------------------|\n| 1 | MS. CLAIBORN:
How about March 28th, next |\n| 2 | Monday? |\n| 3 | MR. HARBACH:
Holley, I didn't get the |\n| 4 | second part of what you said about the 28th. |\n| 5 | MS. CLAIBORN:
I only offered the 28th as a |\n| 6 | new date. |\n| 7 | MR. BALDIGA:
This is Bill Baldiga.
28, 29 |\n| 8 | and 30 Mr. Kwok has a medical issue that he |\n| 9 | (indiscernible)
during those days. |\n| 10 | MS. CLAIBORN:
How about Friday, April 15th? |\n| 11 | MR. HARBACH:
This is David Harbach.
That's |\n| 12 | good by us. |\n| 13 | MR. BALDIGA:
It's Good Friday.
Good Friday |\n| 14 | for me and Passover for many. |\n| 15 | Can I suggest (indiscernible)? |\n| 16 | MS. CLAIBORN:
I didn't hear your |\n| 17 | suggestion. I'm sorry. |\n| 18 | MR. BALDIGA:
I respectfully ask that we go |\n| 19 | back to April 4.
One lawyer among a dozen and one |\n| 20 | creditor should not -- |\n| 21 | MR. WOLMAN:
This is Jay Wolman. I already |\n| 22 | have something for that day as well. |\n| 23 | MR. BALDIGA:
I know, but there are |\n| 24 | (indiscernible)
-- |\n| 25 | MR. WOLMAN:
Two lawyers, including myself, |\n\n| Case 22-50073 | Doc 404-7
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79 | | | |\n| 1 | who is in the middle of questioning. | | | |\n| 2 | MR. BALDIGA:
All right. We'll keep looking | | | |\n| 3 | then. | | | |\n| 4 | MS. CLAIBORN:
Does April 6th work? | | | |\n| 5 | MR. WOLMAN:
What was that date? | | | |\n| 6 | MS. CLAIBORN:
April 6th? | | | |\n| 7 | MR. HARBACH:
This is David Harbach. I can | | | |\n| 8 | do April 6th. | | | |\n| 9 | MR. BALDIGA:
The debtor can as well. | | | |\n| 10 | UNIDENTIFIED:
As can I. | | | |\n| 11 | MS. CLAIBORN:
Okay. I'm going to mark April | | | |\n| 12 | 6th 10:00 a.m.
It's in person.
The U.S. Trustee's | | | |\n| 13 | Office in New Haven. | | | |\n| 14 | Please allow for time to go through | | | |\n| 15 | security. I'd like to start at 10:00. | | | |\n| 16 | MR. BALDIGA:
Could I ask how much time | | | |\n| 17 | would you reserve on that day, including with the | | | |\n| 18 | interpreter, just so we can plan? | | | |\n| 19 | MS. CLAIBORN:
I think you should plan for | | | |\n| 20 | the whole day but I will have to follow up and get | | | |\n| 21 | an understanding about an interpreter and I don't | | | |\n| 22 | have that at my fingertips right now. | | | |\n| 23 | MR. BALDIGA:
Okay.
Would that be 5 | | | |\n| 24 | o'clock? | | | |\n| 25 | I guess we can go off the record as we | | | |\n\n| Case 22-50073 | Doc 404-7
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80 |\n| 1 | finish this.
It's up to you, obviously. |\n| 2 | MS. CLAIBORN:
Okay.
I think we're |\n| 3 | concluded for purposes of Bin's translation services |\n| 4 | for today. |\n| 5 | THE INTERPRETER:
Thank you. |\n| 6 | MS. CLAIBORN:
Thank you very much, Bin. |\n| 7 | THE INTERPRETER:
Have a nice day. |\n| 8 | MS. CLAIBORN:
Thank you. |\n| 9 | I'm going to stop the recording, but we can |\n| 10 | stay on the line.
I'm going to stop the recording. |\n| 11 | Thank you. |\n| 12 | (Meeting adjourned.) |\n| 13 | |\n| 14 | |\n| 15 | |\n| 16 | |\n| 17 | |\n| 18 | |\n| 19 | |\n| 20 | |\n| 21 | |\n| 22 | |\n| 23 | |\n| 24 | |\n\n Ho Wan Kwok - March 21, 2022 83\n\n1 I, CHRISTINE FIORE, court-approved transcriber and 2 certified electronic reporter and transcriber, 3 certify that the foregoing is a correct transcript 4 from the official electronic sound recording of the 5 proceedings in the above-entitled matter. 6\n\n8 April 5, 2022\n\n81\n\n9 Christine Fiore, CERT\n\n10 Transcriber\n\n7\n\n11\n\n12\n\n13\n\n14\n\n15\n\n16\n\n17\n\n18\n\n19\n\n20\n\n21\n\n22\n\n23\n\n24\n\n| Case 22-50073 | Doc 404-7
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83 | Page 83 of |\n|---------------|----------------------------------------------------------------|------------|\n| | Ho Wan Kwok - March 21, 2022 | 82 |\n| 1 | INDEX | |\n| 2 | | |\n| 3 | HO WAN KWOK | Page |\n| 4 | Examination by Ms. Claiborn | 14 |\n| 5 | Examination by Mr. Wolman | 58 |\n| 6 | | |\n| 7 | | |\n| 8 | | |\n| 9 | | |\n| 10 | | |\n| 11 | | |\n| 12 | | |\n| 13 | | |\n| 14 | | |\n| 15 | | |\n| 16 | | |\n| 17 | | |\n| 18 | | |\n| 19 | | |\n| 20 | | |\n| 21 | | |\n| 22 | | |\n| 23 | | |\n| 24 | | |\n| 25 | | |","body_zh":null,"key_entities":["Kwok","Ho Wan Kwok","Guo","Chinese Communist Party","Je","CIPA"],"ecf_references":[{"doc_number":1,"court":"CTB"},{"doc_number":77,"court":"CTB"},{"doc_number":78,"court":"CTB"},{"doc_number":79,"court":"CTB"}],"word_count":21968,"status":"published","published_at":"2022-05-20 00:00:00","created_at":"2022-05-20","updated_at":"2026-07-07 08:20:04"}