{"id":"court_sdny_431_0","court":"SDNY","case_no":"","doc_number":431,"sub_number":null,"doc_type":"DOC","filed_date":"2024-07-23","title":"SDNY ECF 431","summary_zh":null,"summary_en":null,"body_en":"O6IBGUO1\n1 UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n2 ------------------------------x\nUNITED STATES OF AMERICA,\n3\nv. 23 Cr. 118 (AT)\n4\nMILES GUO,\n5\nDefendant. Trial\n6 ------------------------------x\nNew York, N.Y.\n7 June 18, 2024\n9:30 a.m.\n8\nBefore:\n9\n10 HON. ANALISA TORRES,\n11 District Judge\n-and a Jury-\n12\nAPPEARANCES\n13\nDAMIAN WILLIAMS\n14 United States Attorney for the\nSouthern District of New York\n15 BY: RYAN B. FINKEL\nJULIANA N. MURRAY\n16 Assistant United States Attorneys\n17 SABRINA P. SHROFF\nAttorney for Defendant\n18\nPRYOR CASHMAN LLP\n19 Attorneys for Defendant\nBY: SIDHARDHA KAMARAJU\n20 MATTHEW BARKAN\nCLARE P. TILTON\n21\nALSO PRESENT:\n22 Isabel Loftus, Paralegal Specialist, USAO\nRobert Stout, Special Agent, FBI\n23 Ruben Montilla, Defense Paralegal\nTuo Huang, Interpreter (Mandarin)\n24 Shi Feng, Interpreter (Mandarin)\nYu Mark Tang, Interpreter (Mandarin)\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1\n1 (Jury not present)\n2 THE COURT: Would you make your appearances, please.\n3 MS. MURRAY: Good morning, your Honor. Juliana Murray\n4 on behalf of the United States. I'm joined by Paralegal\n5 Specialist Isabel Loftus and FBI Special Agent Robert Stout.\n6 THE COURT: Have you seen the defense attorneys?\n7 MS. MURRAY: I have not seen them yet this morning,\n8 your Honor.\n9 THE COURT: I will ask my staff to advise me as to\n10 when they arrive. I see Ms. Shroff now.\n11 MS. SHROFF: Good morning, your Honor.\n12 THE COURT: Would you make your appearance, please.\n13 MS. SHROFF: Sabrina Shroff on behalf of Mr. Guo who\n14 is standing to my left.\n15 THE COURT: You may be seated. Are there any issues\n16 that either side would like to raise?\n17 MS. MURRAY: Nothing from the government, your Honor.\n18 MS. SHROFF: Nothing from the defense, your Honor.\n19 Thank you.\n20 THE COURT: All righty. We'll start with the witness\n21 on the stand at 9:29. Thank you.\n22 (Recess)\n23 (Continued on next page)\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1\n2 (Jury not present)\n3 THE COURT: Good morning, and would you have the\n4 jurors brought in.\n5 THE LAW CLERK: Jury entering.\n6 (Jury present)\n7 THE COURT: Please be seated. Good morning, jurors.\n8 I apologize that your breakfast was not in the jury room until\n9 9:30 this morning. You were here on time, but the breakfast\n10 wasn't. This is not the first time that food has been late. I\n11 want you to know that my staff has been reminding the cafeteria\n12 of our schedule. But because there's been so much lateness,\n13 I'm personally going to go down to the cafeteria and speak with\n14 them. So we're getting started later than we expected. I\n15 apologize. We're going to continue with the direct examination\n16 of Ms. Reyes. You may continue the inquiry.\n17 MR. FINKEL: Thank you, your Honor.\n18 LIMARIE REYES, resumed.\n19 DIRECT EXAMINATION CONTINUED\n20 BY MR. FINKEL:\n21 Q. Good morning, Ms. Reyes.\n22 A. Good morning.\n23 Q. I remind you you're still under oath. Okay?\n24 A. Yes.\n25 Q. Ms. Reyes, yesterday we talked about something called\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 G Talks. You recall that?\n2 A. Yes.\n3 Q. Who set the budget for G Talks?\n4 A. I was provided the budget by Yvette.\n5 Q. And what was the approximate budget for each of the G Talks\n6 event?\n7 A. The second G Talks event was 2.5 million. The first one, I\n8 don't recall, around 1, 1.5.\n9 Q. 1.5 million?\n10 A. Yes, correct.\n11 Q. Did those numbers, the 1.5 million and 2.5 million include\n12 the cost of any giveaways for the sweepstakes?\n13 A. Yes, that included the cost of the sweepstakes.\n14 Q. You mentioned also yesterday I believe there was\n15 approximately 14 other employees during your time at G/Clubs?\n16 A. Yes.\n17 Q. And those employees were located in Puerto Rico?\n18 THE COURT: Both of you please get closer to the\n19 microphone and raise your voices so that everyone can hear.\n20 MR. FINKEL: Certainly, your Honor.\n21 Q. What departments or roles did those employees have in\n22 Puerto Rico?\n23 A. The departments that we had was finance department, the\n24 legal department, HR department. We had events, marketing,\n25 partnership and membership.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 Q. And those employees reported to who?\n2 A. They were to report to their direct supervisor and those\n3 would report directly to me.\n4 Q. And who did you report to?\n5 A. I reported to the owner Mr. He and to Yvette as well.\n6 Q. Was Mr. He referred to by something other than his name\n7 Mr. He?\n8 A. UBO.\n9 Q. That was a term used within the office?\n10 THE COURT: What was that term again?\n11 THE WITNESS: UBO.\n12 THE COURT: UBO?\n13 THE WITNESS: Yes.\n14 Q. Standing for?\n15 A. Ultimate beneficial owner.\n16 Q. When approximately did you become the interim CEO?\n17 A. February 2021.\n18 Q. And what is your understanding of who selected you to\n19 become the interim CEO?\n20 A. I was provided or I was asked by Zee, the former CEO, and\n21 Jessica.\n22 Q. Did you understand who Zee and Jessica consulted with to\n23 determine whether you would be CEO?\n24 MR. KAMARAJU: Objection.\n25 THE COURT: I have to remind you to raise your voice\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 because even I'm having some difficulty hearing every sentence\n2 clearly. The objection is sustained.\n3 Q. Did Zee or Jessica mention anything about Yvette's view\n4 about you becoming interim CEO?\n5 MR. KAMARAJU: Same objection.\n6 THE COURT: I'm going to allow the question.\n7 Q. You can answer.\n8 A. Yes.\n9 Q. What did they say?\n10 A. That they had discussed with Yvette.\n11 Q. And Yvette's view is what?\n12 A. Positive to me being the interim CEO.\n13 Q. And what did your salary become when you became the interim\n14 CEO?\n15 A. To the best of my recollection 160,000.\n16 Q. How did you learn that you became the CEO?\n17 A. I received an email from HR stating that I was going to be\n18 CEO.\n19 Q. And who selected you to become the CEO?\n20 A. Yvette.\n21 Q. What did your salary become when you became the CEO?\n22 A. 176.\n23 Q. And that's per year?\n24 A. Annual, yes, correct.\n25 Q. Were you entitled to any bonuses?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 A. Yes.\n2 Q. Can you describe to the jury what bonuses you were entitled\n3 to?\n4 A. Yes. There was a Puerto Rican Christmas bonus that's\n5 standard per law, and a yearly bonus, but that would depend on\n6 the different years.\n7 Q. What was the Puerto Rican Christmas bonus?\n8 A. The amount, it's a percentage. It is around $600, $700.\n9 Q. And what do you mean by Puerto Rican Christmas bonus?\n10 A. In Puerto Rico there is an employee law that entitles\n11 Puerto Ricans to receive Christmas bonuses.\n12 Q. In addition to the Puerto Rican Christmas bonus, you said\n13 there was another bonus?\n14 A. Yes.\n15 Q. And how much was that bonus for you?\n16 A. It range from year to year, but to the best of my\n17 recollection maybe 5,000.\n18 Q. And you were the interim CEO for approximately how long?\n19 A. From February to around summer, couple of months.\n20 Q. And you were the CEO for how long?\n21 A. Since summer 2021 up until my resignation.\n22 Q. Which was in what month and what year?\n23 A. March 2023.\n24 Q. What was your understanding of where Yvette worked?\n25 A. In New York.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 THE COURT: Ms. Reyes, if you could get very close to\n2 the microphone very, very close and raise your voice.\n3 Q. Why did Yvette work in New York while G/Clubs was in Puerto\n4 Rico?\n5 A. I do not know. She was there since I started.\n6 Q. Did you ask Yvette why she worked in New York and you\n7 worked in Puerto Rico?\n8 A. No, I did not.\n9 Q. Where did Miles Guo work?\n10 A. I seen him in the New York office.\n11 Q. How many times had you been to the New York offices?\n12 A. More than ten.\n13 Q. Ms. Loftus, if we can display what's in evidence two\n14 exhibits GX-132 and GX131.\n15 Start with the image on the left side of your screen\n16 GX-132, do you recognize that?\n17 A. Yes.\n18 Q. What is it?\n19 A. One of the New York office buildings.\n20 Q. Where approximately was that office building located?\n21 A. I do not know the exact address, but using as reference if\n22 you're looking at the map and there's Central Park, to the\n23 right side.\n24 Q. Have you been inside that building?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 Q. How many floors were in that building approximately in\n2 GX-132?\n3 A. More than three.\n4 Q. Where was Guo's office?\n5 A. In this building in one of the higher floors.\n6 Q. Where was Yvette's office?\n7 A. They shared office.\n8 Q. What other companies worked in that building in GX-132 to\n9 your knowledge?\n10 A. I saw G Fashion team, finance team. There were legal\n11 departments, Rule of Law Foundation. Those are the ones that I\n12 recall.\n13 Q. The image in the right side of your screen GX-131, what is\n14 that?\n15 A. The other New York office space.\n16 Q. Where roughly is that office space located that?\n17 A. That would be to the left of Central Park.\n18 Q. What other companies worked in that office space on the\n19 right side GX-131?\n20 A. There was G Fashion, HCHK, Gettr, and other people that I\n21 don't know exactly.\n22 Q. Ms. Loftus, can you take down the image on the right and\n23 pull up GX-110.\n24 Who is the individual depicted in GX-110?\n25 A. Max.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 Q. Did you observe where Max worked in the building on GX-132,\n2 what floor?\n3 A. I'm not sure if it's fourth, second or third, but it was\n4 the finance department.\n5 Q. Did you observe Max interact with Yvette?\n6 A. In this particular specific building?\n7 Q. In any building?\n8 A. Yes.\n9 Q. Based on your observations, what was your understanding of\n10 the nature of Yvette and Max's relationship?\n11 MR. KAMARAJU: Objection.\n12 THE COURT: Overrule. You can answer.\n13 A. Could you repeat the question.\n14 Q. Based on what you saw and heard, what was your\n15 understanding of the nature of Yvette and Max's relationship?\n16 A. Like what did they talk about?\n17 Q. Yeah.\n18 A. They had meetings, and the things that I recall were with\n19 regards to information about different assets that we're\n20 working on.\n21 Q. And did you have an understanding whether Max reported to\n22 Yvette or Yvette reported to Max?\n23 A. I'm not sure.\n24 Q. You can take those down. Who's Long Island David?\n25 A. My interactions with him, the ones I recall, were with\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 regards to G Talks. He supported on the second G Talks.\n2 Q. Do you know what farm Long Island David was apart of?\n3 A. No.\n4 Q. Did you ask him?\n5 A. No.\n6 Q. If we can pull up what's in evidence as GX-441, GXGC-441.\n7 Thank you.\n8 Ms. Reyes, do you see your name in the CC line of this\n9 email?\n10 A. Yes.\n11 Q. And what is the subject of this email?\n12 A. It's information regarding HCHK employees.\n13 Q. What is HCHK Technologies?\n14 A. HCHK is a vendor that provided support on different\n15 departments.\n16 Q. Did HCHK provide support to G/Clubs?\n17 A. Yes.\n18 Q. Why did you hire HCHK?\n19 A. HCHK, I did not hire it. It was an instruction given, but\n20 it was hired to support with the technical, like the ITT\n21 finance and legal and HR.\n22 Q. Who gave the instruction to hire HCHK for G/Clubs?\n23 A. Yvette.\n24 Q. Did you ask her why HCHK was selected?\n25 A. Yes, I inquire why HCHK was.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 Q. And what was the reason for that?\n2 A. We had a previous contract with GTV, and once that contract\n3 was canceled, then we replaced it with HCHK.\n4 Q. On this email are some other domains. You see it says\n5 Gettr right there?\n6 A. Yes.\n7 Q. There's G Fashion, G/Clubs, HCHKTech, do you have an\n8 understanding why HCHKTech was emailing G Fashion email\n9 address, a G/Clubs email address and a Gettr email address?\n10 A. No.\n11 Q. We can take that down.\n12 Ms. Reyes, have you ever been to London?\n13 A. Yes.\n14 Q. Did you travel to London as a G/Clubs employee?\n15 A. I traveled to the UK, yes.\n16 Q. Who asked you to travel to the UK?\n17 A. Yvette.\n18 Q. And who did you go with?\n19 A. In the plane?\n20 Q. Who did you go with?\n21 A. I went with Alex, Dowa, Kamel and Manuel.\n22 Q. What was the last one?\n23 A. Manuel.\n24 Q. Who is Alex?\n25 A. Alex was a comptroller for G/Clubs.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 Q. What's his last name?\n2 A. Hadjicharalambous.\n3 Q. And who's Dowa.\n4 A. Dowa was a CEO for G Fashion.\n5 Q. And who's Manuel?\n6 A. An attorney for HCHK.\n7 Q. And what were you told was the purpose of your trip to the\n8 UK?\n9 A. My purpose was to visit one of the potential partners that\n10 we were in communications with and to meet with Mr. He.\n11 Q. How did all of you travel to the UK?\n12 A. In a private jet.\n13 Q. Had you been in a private jet before?\n14 A. No.\n15 Q. What potential partner did you meet with in the UK?\n16 A. Company is L&R Properties.\n17 Q. And what do they do?\n18 A. They had, I think they had hotel chains.\n19 Q. Did L&R properties form a relationship with G/Clubs?\n20 A. Ultimately did not.\n21 Q. Can we pull up GX-103. Do you know who this individual is?\n22 A. To the best of my recollection William Je.\n23 Q. Have you ever met William Je?\n24 A. Yes.\n25 Q. Where did you meet him?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 A. In the offices of the Himalaya Exchange.\n2 Q. And when did you go to the offices of the Himalaya\n3 Exchange?\n4 A. On that trip to London.\n5 Q. And why did you go to the offices of the Himalaya Exchange?\n6 A. That was the request to go and meet with them for -- they\n7 were going to give us information about the H Pay app.\n8 Q. Who made the request for you to go to the Himalaya Exchange\n9 offices?\n10 A. To the best of my recollection Yvette.\n11 Q. And you said the H Pay app?\n12 A. Yes.\n13 Q. What's that?\n14 A. It's an app that facilitates member payments.\n15 Q. Why is it called H Pay?\n16 A. I do not know.\n17 Q. Did G/Clubs use H pay to accept member payments?\n18 A. Yes.\n19 Q. Who made the decision to allow members to use H Pay?\n20 A. That request came from Yvette and Mr. He.\n21 Q. What happened during the meeting with William Je in the\n22 Himalaya Exchange offices?\n23 A. We got introduced and then they took us to meet with the\n24 technical team where they provided insight of the development\n25 of the H Pay app. Later on we met their legal team with the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 rights to the contract. That was the concept of the meeting.\n2 Q. How did it work? How did the H Pay app accept payments and\n3 get payments to G/Clubs?\n4 A. I'm not exactly sure.\n5 Q. Did G/Clubs consider using other applications aside from H\n6 Pay?\n7 A. Apps? No, that was the one that we had.\n8 THE COURT: Ms. Reyes, have you made presentations\n9 during your professional career?\n10 THE WITNESS: Like?\n11 THE COURT: Presentations, speaking to a group of\n12 people.\n13 THE WITNESS: Yes.\n14 THE COURT: Okay. So when you speak to a group of\n15 people, you want them to hear what you have to say, right?\n16 THE WITNESS: Yes.\n17 THE COURT: So think of this in that way that you want\n18 to make yourself heard because your voice is so low that people\n19 are straining to hear what you say. I would like them to hear\n20 what you say, so please speak up.\n21 Q. Ms. Loftus, we can pull up GXGC-293 which is in evidence.\n22 If you can blow up the bottom email, please.\n23 Ms. Reyes, who is this email from?\n24 A. Tanu.\n25 Q. At what domain?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO1 Reyes- Direct\n1 A. Himalaya Exchange.\n2 Q. Can you read the second sentence of the email beginning as\n3 discussed?\n4 A. As discussed, please fine attached document for more\n5 information on agreement which G/Club needs to follow to\n6 integrate with Himalaya Pay.\n7 Q. Zoom out of that, please. We can take that down.\n8 Did G/Club have an account with the Himalaya Exchange?\n9 A. To the best of my understanding, yes.\n10 Q. And whose idea was it for G/Clubs to have an account with\n11 the Himalaya Exchange?\n12 A. It was the requirement in order to have the H Pay app.\n13 (Continued on next page)\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 BY MR. FINKEL:\n2 Q. Aside from H Pay, what other methods did G|CLUBS use to\n3 obtain payments from members?\n4 A. Depending on the time, but there was wire payments, checks,\n5 and the H Pay.\n6 Q. Where were the checks sent to?\n7 A. Our offices in Puerto Rico.\n8 Q. And after the checks were received in your offices in\n9 Puerto Rico, what, if anything, happened to them?\n10 A. Depending on the time, we would send them to New York, for\n11 them to be deposited at the banks, and other times it was to\n12 the banks in Puerto Rico.\n13 Q. How would you in Puerto Rico send the checks to New York?\n14 A. Via mail.\n15 Q. And who would receive them in New York?\n16 A. Alex.\n17 Q. You also said wires. What do you mean by that?\n18 A. There was a time where members could pay via wire.\n19 MR. FINKEL: If we can pull up what's marked for\n20 identification as GX 118.\n21 Q. Who is this?\n22 A. Haitham Khaled.\n23 MR. FINKEL: Government offers 118.\n24 MR. KAMARAJU: No objection.\n25 THE COURT: It is admitted.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 (Government's Exhibit 118 received in evidence)\n2 Q. What is Crane?\n3 A. Crane is like a——an escrow agent.\n4 Q. And what role did Crane have, if any, with respect to\n5 receiving member payments?\n6 A. They would receive member payments.\n7 Q. How did members know to send payments to Crane?\n8 A. I do not know.\n9 Q. Did you ask anyone how members knew to send payments to\n10 Crane?\n11 A. I do not recall.\n12 MR. FINKEL: You can take that down.\n13 And if we can pull up what's been marked for\n14 identification as GX 106.\n15 Q. Who is this?\n16 A. Alex.\n17 MR. FINKEL: Government offers 106.\n18 MR. KAMARAJU: No objection.\n19 THE COURT: It is admitted.\n20 (Government's Exhibit 106 received in evidence)\n21 Q. And when you say Alex, Alex?\n22 A. Hadjicharalambous.\n23 Q. And his role was what?\n24 A. Comptroller for G|CLUBS.\n25 Q. What was your understanding of why he worked in New York\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 instead of Puerto Rico?\n2 A. I don't know. He was there before I started.\n3 MR. FINKEL: We can take that down.\n4 If you could pull up what's in evidence as GX GC450.\n5 And go to the next page, please, Ms. Loftus.\n6 Can you zoom in on that.\n7 Q. Who is this email from?\n8 A. David Fallon.\n9 Q. Who is that?\n10 A. He was a part of the Himalaya Exchange team. I met with\n11 him there.\n12 Q. You met with him where?\n13 A. On the offices.\n14 Q. All right. And what does this email say, from him?\n15 A. \"Hi, Limarie,\n16 \"Mr. He has instructed us to execute the attached OTC\n17 transaction.\n18 \"Can you please sign and email back the attached\n19 transaction receipt and I will process the OTC deal.\"\n20 Q. What does that mean, OTC transaction?\n21 A. I'm not exactly sure.\n22 MR. FINKEL: Zoom out of that, please. And if you can\n23 go to the next page.\n24 Q. What does that say at the top?\n25 A. \"Himalaya Exchange OTC Transaction Form.\"\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. And in the middle, it says Transfer to Buyer. Can you read\n2 that.\n3 A. Yes. \"Buyer receives: +500k, HCN at 31.500 per HCN.\n4 \"Buyer pays: 15,750,000 HDO.\"\n5 Q. What was the name of the buyer account?\n6 A. Billing@gclubs.com.\n7 Q. Who signed this?\n8 A. Alex.\n9 Q. What is your understanding of why G|CLUBS purchased\n10 15.7 million HDO?\n11 A. I do not know.\n12 Q. Did you ask Mr. He why G|CLUBS was purchasing 15.7 million\n13 HDO?\n14 A. I do not recall.\n15 Q. Did you ask Yvette?\n16 A. I do not recall.\n17 Q. Would buying HDO provide member benefits?\n18 A. I do not know.\n19 MR. FINKEL: We could take that down.\n20 Q. Your trip to the UK, did you travel to any other countries?\n21 A. Yes.\n22 Q. Which ones?\n23 A. Naples.\n24 Q. Why did you travel to Naples?\n25 A. To meet with Mr. He.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. Who did you travel with?\n2 A. To Naples, with Alex.\n3 Q. Just you and Alex?\n4 A. Yes.\n5 Q. Where did you meet Mr. He?\n6 A. In a boat.\n7 Q. Was anyone else in the boat?\n8 A. Yes.\n9 Q. Who?\n10 A. Mileson.\n11 Q. What was the name of the boat?\n12 A. Lady May.\n13 Q. What time of day did you meet Mileson, Mr. He, in the Lady\n14 May?\n15 A. The time? I don't recall specifically.\n16 Q. Was it evening, afternoon?\n17 A. Yes, it was late evening.\n18 Q. Late evening?\n19 A. Yeah.\n20 Q. Can you describe what the Lady May is like.\n21 A. It's a big boat, with different floors.\n22 Q. How long were you and Alex on the Lady May with Mileson and\n23 Mr. He?\n24 A. Couple hours.\n25 Q. How did you get to the Lady May?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. From the pier. So we got to the pier, and then there was a\n2 smaller boat that took us there.\n3 Q. What did you do with Mr. He and Mileson and Alex on the\n4 Lady May for a couple of hours?\n5 A. We had dinner.\n6 Q. What did you guys discuss?\n7 A. To the best of my recollection, we learned that they had\n8 met since college, talked about their——their likes. One had\n9 likes for water, like scuba diving, the other one for race\n10 cars. I believe we talked about our visit to the hotels,\n11 partnership; kind of like a collection of that day.\n12 Q. I'll just ask you to please speak up and speak clearly into\n13 the microphone.\n14 A. Yes.\n15 Q. Who said they liked race cars?\n16 A. Mileson.\n17 Q. Sorry?\n18 A. Mileson.\n19 Q. And who said that that he liked scuba diving?\n20 A. Mr. He.\n21 Q. Did you discuss with Mileson and Mr. He taking down the\n22 Chinese Communist Party?\n23 A. Not that I recall.\n24 Q. Did you discuss Chinese politics?\n25 A. Not that I recall.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. Did you discuss the whistleblower movement?\n2 A. Not that I recall.\n3 Q. The New Federal State of China?\n4 A. Not that I recall.\n5 Q. What did Mr. He refer to Mileson as on the boat? What name\n6 did he use?\n7 A. To the best of my recollection, Mileson.\n8 Q. Did there come a time, if ever, when you were asked to\n9 facilitate purchases of assets for G|CLUBS?\n10 A. Yes.\n11 Q. And who asked you to do that?\n12 A. Depending. It could come from Yvette or Mr. He.\n13 Q. What sort of assets were purchased for G|CLUBS?\n14 A. Vehicles, and there was a boat.\n15 Q. And what?\n16 A. Boat.\n17 Q. What vehicles?\n18 A. There was a Lamborghini, camper van, and a Bugatti.\n19 Q. And what sort of boat?\n20 A. I believe it was a 70 feet yacht.\n21 Q. What were you told was the reason for these asset\n22 purchases?\n23 A. We were going to be offering as potential benefits for\n24 members.\n25 Q. And by potential benefits, what, if anything, would members\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 have to pay to use these assets?\n2 A. We had not decided on what was going to be the payment.\n3 Q. Was it your understanding that the assets were going to be\n4 free to use or cost money?\n5 A. No, to my understanding they were going to be like renting,\n6 so they were going to cost.\n7 Q. Did you say renting?\n8 A. Yes, like when you would rent a car for an amount, yeah.\n9 Q. Again, please speak loudly into the mic.\n10 Ms. Reyes, what was done, if anything, during your\n11 entire time at G|CLUBS to implement a procedure to allow\n12 members to rent these assets, the cars and the boat?\n13 A. We had reached out to a firm in order to put in place a\n14 contract as to how to do that negotiation.\n15 Q. And when did you reach out to the firm about that?\n16 A. To the best of my recollection, maybe around early 2022.\n17 Q. Okay. And after that reaching out to the firm in early\n18 2022, what actions, if any others, were taken to put in place a\n19 process to allow members to rent these assets?\n20 A. That was all we had done.\n21 Q. You mentioned a Lamborghini. Who from the New York office,\n22 if anyone, directed you to facilitate a purchase of a\n23 Lamborghini?\n24 MR. KAMARAJU: Objection to foundation.\n25 MR. FINKEL: I'll withdraw.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 THE COURT: Sustained.\n2 MR. FINKEL: I'll withdraw.\n3 If we can pull up GX GC276, which is in evidence.\n4 Could you go to bottom of this, or not quite the\n5 bottom, the last email.\n6 Keep going, please, Ms. Loftus.\n7 Right there. Can you zoom in on that.\n8 BY MR. FINKEL:\n9 Q. The September 10, 2021 email, who is it from?\n10 A. Bo Collins.\n11 Q. Who is Bo Collins?\n12 A. The president of Mercantile Bank.\n13 Q. Had you ever met him?\n14 A. In person? Yes.\n15 Q. Where?\n16 A. At his home.\n17 MR. FINKEL: We can zoom out of that.\n18 And if you can scroll up, please, Ms. Loftus. So\n19 right there, September 10th email. No.\n20 Yeah.\n21 Q. Who is this email from?\n22 A. Max.\n23 Q. Max who?\n24 A. Max Krasner.\n25 Q. And what's his email address?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Maxk@lampcapital.org.\n2 Q. What's Lamp Capital?\n3 A. I do not know.\n4 Q. And can you read what Max wrote.\n5 A. \"Hi, Ana,\n6 \"Looks like the team is staying with the red Lambo.\n7 We need to finalize all paperwork. Officer resolutions naming\n8 officer and allowing the purchase of the vehicle. We need a\n9 drivers license, and a wire payment.\"\n10 Q. Did you receive this email?\n11 A. Yes, I was copied.\n12 Q. What was your understanding of what Max meant by \"the team\n13 is staying with the red Lambo\"?\n14 A. To the best of my understanding, Yvette.\n15 MR. FINKEL: You can zoom out of that, please, and\n16 scroll up, please, Ms. Loftus. Zoom in on that email.\n17 No, the one below it, please. Thank you.\n18 Q. Can you read what Ana wrote to Max.\n19 A. \"Hi Max.\n20 \"As discussed, it is past cut off and we do not have\n21 the documents signed by Mr. He (including the resolution you\n22 need). Once Limarie gets them, she can send them and the wire\n23 can go out on Monday.\"\n24 Q. Stop there. What was your role in facilitating the\n25 purchase of this red Lambo?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. I would get the documents for the loan and the resolutions,\n2 and I would send them to Mr. He for his signature.\n3 Q. Who would you get the documents from?\n4 A. Sorry?\n5 Q. Withdrawn. What do you mean by the loan?\n6 A. There were set of loans that were done in order to purchase\n7 the asset, so these are the documents for that.\n8 Q. And can you describe what entity loaned to what entity.\n9 A. There was G Club Operations, G Club International BVI.\n10 Q. BV?\n11 A. BVI.\n12 Q. What's G Club Operations?\n13 A. What is? The G Club is a membership company.\n14 Q. And where did G Club Operations get its money from?\n15 A. Membership payments.\n16 Q. And G|CLUBS Operations would send a loan to G Club BVI?\n17 A. Yes.\n18 THE COURT: Are you saying that Operations was the\n19 lender, G|CLUBS Operations?\n20 THE WITNESS: Correct.\n21 Q. And Operations was based where, to your understanding?\n22 A. Puerto Rico.\n23 Q. And G Club BVI was based where, to your understanding?\n24 A. BVI.\n25 Q. How many employees did G|CLUBS BVI have?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. None, to my understanding.\n2 Q. What do you mean not to your understanding?\n3 A. None, none. Sorry. None to my understanding.\n4 THE COURT: So I'm going to try using the handheld\n5 microphone to see if that will work better.\n6 Q. Who was the ultimate beneficial owner of G|CLUBS BVI?\n7 A. To my understanding, Mr. He.\n8 Q. Why, as the CEO of G|CLUBS, did you structure assets in\n9 this manner?\n10 A. I did not structure the asset purchases in this manner.\n11 Q. Did you ask Yvette why they were structured in this manner?\n12 A. The asset purchases? Not that I recall.\n13 Q. What about Mr. He, did you ask him why they were structured\n14 in this manner?\n15 A. Not that I recall.\n16 MR. FINKEL: Is the handheld mic better or worse?\n17 THE COURT: Members of the jury?\n18 THE JURORS: Worse.\n19 THE COURT: This is worse. All right. So we'll go\n20 back to using the other microphone.\n21 MR. FINKEL: Ms. Reyes, feel free to move the\n22 microphone to make yourself comfortable, and try to point the\n23 microphone directly at your mouth where your voice is coming\n24 out, and just speak as loudly and clearly as you can so\n25 everyone can hear you.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 THE COURT: Ms. Reyes, see how it bends like this?\n2 You can just bend it and get it really close so that everyone\n3 can hear you.\n4 MR. FINKEL: Point it so it's right——\n5 THE WITNESS: Here?\n6 MR. FINKEL: Yeah. Speak right into the microphone,\n7 okay?\n8 Okay. We can zoom out of that. And can you scroll\n9 up, please.\n10 And can you zoom in on the bottom email.\n11 BY MR. FINKEL:\n12 Q. Can you read what Max wrote.\n13 A. \"Thanks, Ana. Here is the updated bill of sale. I will\n14 call the dealer first thing Monday morning to confirm they have\n15 the vehicle and then we can wire the funds. Hopefully we have\n16 Mr. He's signature prior to that.\"\n17 Q. Why was Max in touch with the dealer?\n18 A. To my understanding, Max was the one that was in——managing\n19 the requirement, the documents.\n20 Q. Why was that being managed by someone in New York rather\n21 than Puerto Rico; do you know?\n22 A. I wouldn't know.\n23 MR. FINKEL: Okay. We can zoom out of that. And can\n24 you scroll——can you zoom in on the top email, please,\n25 Ms. Loftus.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. And what's the date of this email, Ms. Reyes?\n2 A. September 11, 2021.\n3 Q. And what did you write?\n4 A. \"Dear All, please find attached signed documents.\"\n5 MR. FINKEL: Okay. Let's zoom out of that. If we can\n6 scroll down, please.\n7 Stop right there.\n8 Q. Okay. What is this document titled?\n9 A. G Club International Limited.\n10 Q. And is this one of the documents that you attached as a\n11 signed document?\n12 A. Could you repeat that.\n13 Q. Is this one of the documents that you attached to your\n14 email as a signed document?\n15 A. Yes, this is the type of form, correct.\n16 Q. Who signed this document?\n17 A. Mr. He.\n18 Q. Are you familiar with what Mr. He's signature looks like?\n19 A. Yes.\n20 Q. All right. Can you read Purpose 1.1.\n21 A. \"The sole director has deemed it to be in the best interest\n22 of the company to request a loan for 2 million USD from its\n23 wholly-owned subsidiary G Club Operations LLC.\"\n24 MR. FINKEL: Can you zoom out of that.\n25 Q. And on the bottom it says Sole Director. Can you read the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 name below Sole Director.\n2 A. Haoran He.\n3 MR. FINKEL: Zoom out of that. And can you zoom in,\n4 Ms. Loftus, on 1.2.\n5 Q. Can you read 1.2, please, Ms. Reyes.\n6 A. \"The Sole Director and the Company are interested in\n7 purchasing a 2021 Lamborghini AVENTSVJRD (VIN Number——\"do you\n8 want me to read it completely?\n9 Q. Yes.\n10 A. \"——ZHWUN6ZD2MLA10393) from Lamborghini Dallas for\n11 832,000.75.\"\n12 Q. Why was Lamborghini Dallas selected as the seller of this\n13 Lamborghini?\n14 A. I do not know.\n15 Q. Did you have any role in selecting Lamborghini Dallas as\n16 the seller of this Lamborghini?\n17 A. No, I did not.\n18 Q. Do you have any role in negotiating the price of this\n19 Lamborghini?\n20 A. No, I did not.\n21 Q. Did you have any role in selecting the model of this\n22 Lamborghini?\n23 A. No, I did not.\n24 MR. FINKEL: You can zoom out of that.\n25 Q. And what does it say at the top?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. \"Written resolutions of the Sole Director of the Company\n2 made in accordance with the Company's Articles of Association.\"\n3 Q. And above that, what's at the very top?\n4 A. \"G Club International Limited, Company No. 2045976.\"\n5 MR. FINKEL: Okay. You can zoom out of that.\n6 And could we go to the next page, please, Ms. Loftus.\n7 Q. Who signed this document?\n8 A. Mr. He.\n9 Q. And what does it say under Written Consent of the Sole\n10 Member at the very top?\n11 A. G Club Operations LLC.\n12 Q. And can you read where it says, \"NOW, THEREFORE, it is:\n13 RESOLVED.\"\n14 A. \"NOW, THEREFORE, it is:\n15 \"RESOLVED, Sole Member deems it to be in the best\n16 interest of the company and hereby authorizes and directs the\n17 company to loan 2 million USD to the sole member for it to\n18 deposit, and under the terms and conditions established in the\n19 loan agreement. For efficiency purposes, the Sole Member\n20 hereby authorizes and directs the company and its authorized\n21 representatives to execute any and all documents necessary to\n22 consummate the loan authorized herein.\"\n23 MR. FINKEL: Zoom out of that, please.\n24 Q. And above that, can you read where it says \"WHEREAS.\"\n25 A. \"WHEREAS, Sole Member has deemed it to be in the best\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 interest of the company to loan $2 million USD at 3 % APR to\n2 the Sole Member for its investment, under the terms and\n3 conditions further stipulated in the loan agreement attached\n4 here to as Exhibit A.\"\n5 Q. Ms. Reyes, to your knowledge did G|CLUBS BVI pay G|CLUBS\n6 Operations for this loan?\n7 A. Not that I was aware of, no.\n8 Q. With respect to any of the assets purchases, did G|CLUBS\n9 BVI make payments to G|CLUBS Operations?\n10 A. Not that I was aware of.\n11 MR. FINKEL: Zoom out of that, please.\n12 Could you scroll down, please, Ms. Loftus. Stop right\n13 there.\n14 Q. What is this document?\n15 A. It's a loan agreement.\n16 Q. Between who?\n17 A. G Club Operations and G Club International Limited.\n18 Q. And G Club Operations is located where?\n19 A. Puerto Rico.\n20 Q. And G Club International Limited is located where?\n21 A. BVI.\n22 Q. And in the G|CLUBS office, what would employees refer to G\n23 Club International Limited as?\n24 A. G Club BVI.\n25 Q. Do you recognize the initials at the bottom of the page?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Yes.\n2 Q. Whose initials are they?\n3 A. Mr. He and mine.\n4 MR. FINKEL: Okay. We can go to the next page,\n5 please, Ms. Loftus.\n6 Q. And can you read, \"Agreed Terms, Loan Proceeds.\"\n7 A. \"Loan Proceeds. The lender hereby agrees to lend to\n8 borrower 2 million USD.\"\n9 Q. Did you write this loan agreement?\n10 A. No, I did not.\n11 Q. Did you ask questions about why it was structured this way?\n12 A. Not that I recall.\n13 MR. FINKEL: You can zoom out of that, please,\n14 Ms. Loftus. And could you go to paragraph 15.\n15 Q. Under Notices, there are three email addresses. Do you see\n16 that?\n17 A. Yes.\n18 MR. FINKEL: Can you zoom in on that, please.\n19 Q. For Lender, what's the email address for Lender?\n20 A. Notices@gclubs.com.\n21 Q. And for Borrower?\n22 A. Coolhhr@protonmail.com, and noticesgclubbvi@protonmail.com.\n23 Q. Who used the email address coolhhr@protonmail.com?\n24 A. Mr. He.\n25 MR. FINKEL: You can zoom out of that.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Can you go to the last page, please, or second to last\n2 page, please, Ms. Loftus.\n3 One more. Thank you.\n4 Q. Who signed this?\n5 A. Mr. He and me.\n6 MR. FINKEL: If we can pull up GX GC300, which is in\n7 evidence.\n8 Q. And at the very top, who is this email from?\n9 A. From me.\n10 Q. Who is it to?\n11 A. Mr. He.\n12 MR. FINKEL: Can you go to page 6, please, Ms. Loftus.\n13 Q. This was attached to your email?\n14 A. I'm sorry?\n15 Q. Was this attached to your email?\n16 A. I didn't——\n17 MR. FINKEL: Let's go back to page 1. Let's go to\n18 page 1, please, Ms. Loftus.\n19 Q. What are the attachments to this email?\n20 A. Letter of authority, motor vehicle buyers order, and\n21 vehicle docs.\n22 MR. FINKEL: And if we can go to page 6, please, of\n23 GX GC300.\n24 Can you zoom in on that.\n25 Q. And who is this letter addressed to?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Mr. He.\n2 Q. What does it say? What name does it say?\n3 A. \"Dear Mr. Haoran.\"\n4 Q. And can you read No. 3 under \"Here is of items needed.\"\n5 A. \"Down payment of funding (wire, cashier's check to\n6 Lamborghini Dallas) (Received)\"\n7 Q. Who signed this letter?\n8 A. EG Louie Bonsukan.\n9 Q. Have you ever spoken with Louie Bonsukan?\n10 A. No, I have not.\n11 Q. Have you spoken with anyone from Lamborghini Dallas?\n12 A. No, I have not.\n13 MR. FINKEL: We can pull up GX GC318. And can you\n14 zoom in on the top email, please.\n15 Q. Who is this email from?\n16 A. From Max.\n17 Q. Can you read what it says.\n18 A. \"Team, Dealer doesn't think they will be able to install\n19 the Lojack, so let's go ahead with the signing of the docs and\n20 wiring the funds in the morning.\n21 \"Additionally, please see the dispatch sheet. The\n22 vehicle will be loaded on Saturday and the planned delivery to\n23 CT is Thursday, September 30th.\n24 \"The cost for shipping is 1,400 and the transport\n25 company will request payment upon delivery. Easiest way is to\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 pay by credit card, otherwise we can ask if they can accept a\n2 wire.\"\n3 Q. Okay. What is your understanding of why——well, withdrawn.\n4 MR. FINKEL: Could we zoom out of that for a moment.\n5 Can you scroll down, please.\n6 Okay. Great. Sorry. Keep going down.\n7 Ms. Loftus, can you scroll up. Keep going.\n8 Stop right there. Can you zoom in at the top email.\n9 Q. Can you just read the first sentence of this email.\n10 A. \"Looks like the team is staying with the red Lambo.\"\n11 MR. FINKEL: Can you zoom out of that, please,\n12 Ms. Loftus. Scroll up.\n13 Keep going. Stop.\n14 And can you zoom in on that email.\n15 Q. Can you read the first sentence.\n16 A. \"The car dealer will work with us to get the car shipped\n17 from Dallas to CT.\"\n18 Q. What was your understanding of what CT means?\n19 A. Connecticut.\n20 Q. Why was the Lamborghini going to be shipped from Dallas to\n21 Connecticut?\n22 A. I do not know.\n23 Q. Have you ever been to Greenwich, Connecticut?\n24 A. No.\n25 Q. Does G|CLUBS have any offices, to your knowledge, in\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Greenwich, Connecticut?\n2 A. Not to my knowledge, no.\n3 MR. FINKEL: Zoom out of that. Scroll up a little\n4 bit.\n5 Stop right there. And can you zoom in to from\n6 team——from Max, actually.\n7 Keep going. Perfect.\n8 Q. Can you read the first sentence.\n9 A. \"We got a lot of declines so far for commercial vehicle\n10 insurance, mainly due to the fact that it's a high end car.\n11 Nonetheless, please see below message in blue from the broker.\"\n12 Q. And can you read the first two bullet points.\n13 A. \"Who are the owners of the Club LLC? Why is the vehicle\n14 being titled to this Club?\"\n15 Second one: \"Has Scott previously owned any other\n16 exotic vehicles? I have attached a résumé of high performance\n17 driving experience if you could fill this out as well.\"\n18 Q. Are you aware of anyone named Scott who worked for Miles\n19 Guo?\n20 A. At the time? At the time of this email, no.\n21 Q. Did you later learn of an individual named Scott who worked\n22 for Miles Guo?\n23 A. I learned of an individual named Scott, correct.\n24 Q. Do you know Scott's last name?\n25 A. I don't recall.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. What is your understanding of what Scott did for Miles Guo?\n2 A. He was like security, security person.\n3 MR. FINKEL: Can we scroll up, please.\n4 Stop right there.\n5 Q. And this email from Ana on September 20, 2021, starts,\n6 \"Good morning Max.\" Can you read the first bullet.\n7 A. \"My first question is who is Scott?\"\n8 MR. FINKEL: Okay. Zoom out of that.\n9 Q. Can you read the second bullet.\n10 A. \"As you know the Lambo was bought outright; not financed\n11 nor leased.\"\n12 Q. Why was Scott involved in the purchase of the red Lambo?\n13 A. I do not know.\n14 Q. Did you ask anyone why?\n15 A. Not that I recall.\n16 MR. FINKEL: We can take that down.\n17 Q. Was the Lamborghini purchased?\n18 A. I believe so, yes.\n19 Q. Was it ever made available to G|CLUBS members?\n20 A. Not that I was aware of, no.\n21 Q. Did you ever see the red Lamborghini in person?\n22 A. Not in person, no.\n23 Q. Did you ever see it in a video?\n24 A. Yes.\n25 Q. When?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. I'm not exactly sure the date. Some point in 2022.\n2 Q. What did you see? Can you describe it to the members of\n3 the jury, please.\n4 A. Yes. It was a video of Mr. Guo showcasing a red\n5 Lamborghini.\n6 Q. And what was your understanding of why Guo was showcasing a\n7 red Lamborghini?\n8 A. As a benefit for members; that was something that they\n9 would be able to receive, or enjoy.\n10 Q. And at the time you saw this video, Ms. Reyes, was the red\n11 Lamborghini available to members?\n12 A. Not at the time.\n13 Q. Was it available to members at any time that you were at\n14 G|CLUBS?\n15 A. No, it was not.\n16 Q. Did you ever speak to Guo about the Lamborghini in this\n17 video?\n18 A. Not that I recall.\n19 Q. What reaction did you have seeing Guo showcasing the red\n20 Lamborghini in this video?\n21 A. What did we do?\n22 Q. How did it make you feel?\n23 A. I was concerned because that was not something that we were\n24 offering at the time.\n25 Q. Did you relay these concerns to anybody?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Yes. Concerns related to the legal department.\n2 Q. Who?\n3 A. Ana.\n4 Q. And what did Ana say, if anything, about the red\n5 Lamborghini?\n6 A. She sought advice from Victor as to how to manage.\n7 Q. Victor who?\n8 A. Victor Cerda.\n9 THE COURT: Where was Victor located?\n10 THE WITNESS: In New York.\n11 MR. FINKEL: If we can display for the witness GX 119.\n12 Q. Who is this individual?\n13 A. Scott.\n14 MR. FINKEL: Government offers 119.\n15 MR. KAMARAJU: No objection.\n16 THE COURT: It is admitted.\n17 (Government's Exhibit 119 received in evidence)\n18 Q. And what is your understanding of Scott's role again?\n19 A. He was security.\n20 Q. For who?\n21 A. For Mr. Guo and the building.\n22 Q. Did you see him when you traveled to New York?\n23 A. In some occasions, yes.\n24 Q. And approximately how many occasions did you see Scott?\n25 A. I'm not exactly sure. A few.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. Did you speak with him on those occasions?\n2 A. Mainly if I crossed in the hallway with him.\n3 Q. Did Scott ever tell you anything about the red Lamborghini?\n4 MR. KAMARAJU: Objection, hearsay.\n5 THE COURT: Overruled. You may answer.\n6 A. Yes, I recall a time where he mentioned about looking for a\n7 warehouse.\n8 Q. And what prompted Scott to tell you——excuse me. Withdrawn.\n9 Ms. Reyes, what, if anything, did you say to Scott\n10 that prompted him to say they were looking for a warehouse?\n11 MR. KAMARAJU: Objection to form.\n12 THE COURT: Did you say anything to him?\n13 Q. Did you say anything to him before Scott said that they\n14 were looking for a warehouse for the red Lamborghini?\n15 A. Not that I recall.\n16 Q. So he said it out of the blue.\n17 A. To the best of my recollection, yes.\n18 Q. Sitting here today, do you know what happened to the red\n19 Lamborghini?\n20 A. I do not know.\n21 Q. Did you authorize the red Lamborghini to be stored\n22 anywhere?\n23 A. No, I did not.\n24 Q. Did you receive updates about where the red Lamborghini\n25 was?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. No, I did not.\n2 Q. Did you ask questions about where the red Lamborghini was?\n3 A. Not that I recall.\n4 Q. Did Mr. He inquire with you about where the red Lamborghini\n5 was?\n6 A. Not that I recall.\n7 Q. What about Yvette?\n8 A. Not that I recall.\n9 Q. What about Miles Guo?\n10 A. No.\n11 MR. HORTON: We can take that down, and on the left\n12 side of the screen, Ms. Loftus, if you could pull up GX GC276,\n13 the fourth page. And can you zoom in on paragraph 1.2.\n14 Can you do it so the rest of the document is visible.\n15 Can you drag that to the bottom.\n16 And on the right side of the screen can you pull up\n17 GX CT41.\n18 BY MR. FINKEL:\n19 Q. Ms. Reyes, can you read the VIN number from 1.2, the\n20 document at the bottom.\n21 A. ZHWUN6ZD2MLA10393.\n22 Q. What is a VIN number?\n23 A. Number that identifies a car.\n24 Q. Say again?\n25 A. A number that identifies a car.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. And can you read the number on the right side of the screen\n2 in CT41.\n3 A. ZHWUN6ZD2MLA10393.\n4 Q. Is that the same number?\n5 A. Yes.\n6 Q. Have you seen that image on the right side of the screen\n7 before?\n8 A. No, I have not.\n9 MR. FINKEL: Ms. Loftus, if you can take down CT41 and\n10 replace it with CT38.\n11 Q. GX CT38, the right side of your screen, Ms. Reyes, where\n12 was that photograph taken?\n13 A. I do not know.\n14 Q. Have you ever seen this photograph before?\n15 A. No.\n16 Q. Who is Defeng Cao?\n17 A. I do not know.\n18 Q. Who is Wayne Cao?\n19 A. I do not know.\n20 Q. Is Wayne Cao an employee of G|CLUBS?\n21 A. No.\n22 Q. Is Defeng Cao an employee of G|CLUBS?\n23 A. No.\n24 MR. FINKEL: We can take that down.\n25 Q. Ms. Reyes, what is a Bugatti?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. A sports car.\n2 Q. Did there come a time, if ever, when Mr. He asked you to\n3 help purchase a Bugatti?\n4 A. Yes.\n5 MR. FINKEL: If we can pull up what's in evidence as\n6 GX GC341.\n7 Q. Who is this email from?\n8 A. Mr. He.\n9 Q. And who is it to?\n10 A. To me.\n11 Q. And what is Mr. He asking you to do?\n12 A. To sign the purchase contract attached and give updates on\n13 the progress of Mr. Ian.\n14 Q. And what's Mr. Ian? What's he involved in?\n15 A. Mr. Ian is the president or owner of the L&R Properties.\n16 Q. The hotel chain you met with when you went to the UK?\n17 A. Correct.\n18 MR. FINKEL: Can you zoom out of that please,\n19 Ms. Loftus. Go to the next page.\n20 Q. What does it say at the top of this document?\n21 A. Supplemental Terms for the Purchase of the Bugatti Chiron\n22 Super Sport.\n23 Q. What's a Chiron Super Sport?\n24 A. The model of the car.\n25 Q. Did G|CLUBS purchase a Bugatti?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. We had a loan, correct.\n2 Q. A loan to who?\n3 A. BVI.\n4 Q. And did BVI purchase a Bugatti?\n5 A. Yes.\n6 Q. And what were you told was the reason BVI was purchasing a\n7 Bugatti?\n8 A. As part of the benefits for the members.\n9 Q. And aside from that law firm you talked to and you said in\n10 2021, was there any other efforts made to set up a way for\n11 members to use a Bugatti?\n12 MR. KAMARAJU: Objection. Misstates the testimony.\n13 Q. Aside from the law firm you spoke to, was there any other\n14 efforts made to make a Bugatti or any other vehicle available\n15 for members?\n16 MR. KAMARAJU: Objection, compound.\n17 THE COURT: If you'll take it piece by piece.\n18 Q. Was the Bugatti ever made available to members of G|CLUBS?\n19 A. No, it was not.\n20 Q. Why did you, Ms. Reyes, as the CEO of G|CLUBS, select a\n21 Bugatti?\n22 A. I did not select a Bugatti.\n23 Q. Who did?\n24 A. Mr. He.\n25 Q. Did you have a discussion with Mr. He about whether it made\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 sense to spend money on a Bugatti?\n2 A. Not that I recall.\n3 Q. Or a Lamborghini?\n4 A. No.\n5 MR. FINKEL: Ms. Loftus, can you zoom in at the top\n6 where it says Buyer.\n7 Q. What's the name listed for Buyer?\n8 A. My name.\n9 Q. Sorry?\n10 A. My name.\n11 Q. Is that your email address, ddimis80@gmail.com?\n12 A. No, it's not.\n13 Q. Is that your telephone number?\n14 A. No, it's not.\n15 MR. FINKEL: You can zoom out of that.\n16 You can scroll down.\n17 Stop right there. And can you zoom in on 2a.\n18 Q. What was the base price for the Bugatti?\n19 A. 3,825,000 U.S. dollars.\n20 MR. FINKEL: If we can pull up, Ms. Loftus, GX GC363.\n21 Q. And what is Mr. He asking you on this document on\n22 November 2, 2021?\n23 A. To please confirm the agreed delivery time.\n24 Q. Was the Bugatti delivered anywhere?\n25 A. Not that I recall.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. Do you know who Lonny Soza is?\n2 A. I'm not exactly sure.\n3 Q. Do you know what Post Oak Motors is?\n4 A. Sorry?\n5 Q. Post Oak Motors.\n6 A. Yes. The dealership for the Bugatti.\n7 Q. Did you communicate with any individuals from Post Oak\n8 Motors in connection with the Bugatti?\n9 A. Yes.\n10 Q. Do you recall who you spoke with?\n11 A. I don't remember the name, but I believe it was like the\n12 president.\n13 Q. Okay. And what were the nature of your communications with\n14 Post Oak Motors?\n15 A. Depending. Changes or modifications and with regard to\n16 payments, and registration.\n17 MR. FINKEL: If we could pull up GX GC522, which is in\n18 evidence.\n19 Q. Who signed this document, Ms. Reyes?\n20 A. Mr. He.\n21 MR. FINKEL: And Ms. Loftus, can you zoom in on\n22 Purpose.\n23 Q. Can you read 1.1.\n24 A. \"The Sole Director and the Company are interested in\n25 purchasing a Bugatti Chiron Super Sport from Bugatti Houston\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 for 3,825,000 U.S. dollars, which may be subject to EUR to USD\n2 exchange rate fluctuations, to transport it, find proper\n3 storage, and to purchase the necessary insurance.\"\n4 MR. FINKEL: Zoom out of that.\n5 Is there another page to this?\n6 Q. You said that the Bugatti was purchased through a loan from\n7 G Club Operations to G Club BVI; is that right?\n8 A. Yes.\n9 Q. Was that loan ever paid back by BVI?\n10 A. Not that I recall.\n11 Q. And the money that was sent from Operations to BVI to\n12 purchase this Bugatti, where did G|CLUBS Operations get that\n13 money from?\n14 A. Member payments.\n15 Q. Did there come a time, if ever, when Mr. He said that he\n16 would contact Post Oak Motors instead of you?\n17 A. Yes.\n18 Q. And did Mr. He explain why?\n19 A. No.\n20 Q. What was going on with Post Oak Motors at that time when\n21 Mr. He said he would take over?\n22 A. That was a time where the car was available and\n23 registration documents needed to be worked on.\n24 Q. What do you mean by the car was available?\n25 A. It was already done, constructed.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. Where was it available from?\n2 A. From the dealership.\n3 Q. Where was the dealership located; do you know?\n4 A. I'm not sure.\n5 Q. And why did Mr. He take over the registration issues with\n6 respect to the Bugatti?\n7 A. I do not know.\n8 MR. FINKEL: If we pull up GX 218.\n9 Q. To your knowledge did anyone ever pick up the car, the\n10 Bugatti?\n11 A. I do not know.\n12 Q. Do you know where this photograph was taken?\n13 A. No.\n14 Q. Have you seen this photograph before?\n15 A. No.\n16 MR. FINKEL: We can take that down.\n17 Q. You mentioned that another asset that was purchased was a\n18 boat; is that right?\n19 A. Yes.\n20 MR. FINKEL: We can pull up GX GC309.\n21 Q. And the top, who is this email from?\n22 A. Mr. He.\n23 Q. And who is it to?\n24 A. To me.\n25 Q. Can you read the subject.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. \"G|CLUBS Loan Documents and Resolutions, G Club\n2 International Limited.\"\n3 Q. And what's attached to it? What are the attachments\n4 called?\n5 A. Written Resolutions and Yacht Contract.\n6 MR. FINKEL: You can zoom out of that.\n7 And can you zoom in on the September 20th email.\n8 Q. Can you read what you wrote to Mr. He on September 20th.\n9 A. \"Please find attached Vessel additional documentation, for\n10 your review and approval signature. G Fashion Hold Co. B\n11 resolution consent to the adoption of the company to enter into\n12 a certain purchase agreement to acquire a Bering 70 vessel with\n13 transport to Boston, MA, USA. Seven Star yacht transport\n14 contract.\"\n15 Q. What is G Fashion Hold Co. B?\n16 A. I'm not sure.\n17 Q. And the Bering 70 vessel, what's that?\n18 A. The boat; the yacht.\n19 Q. What role, if any, did you have in selecting the Bering 70\n20 vessel as something to purchase?\n21 A. I did not have a role.\n22 Q. Did you ask any questions to Mr. He about why G|CLUBS was\n23 purchasing a Bering 70 vessel?\n24 A. I did not.\n25 Q. What about with Yvette?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Not that I recall.\n2 MR. FINKEL: You can zoom out of that, please. And if\n3 you can scroll down. Keep going.\n4 Bit more, please.\n5 Stop right there.\n6 Q. What does it say at the top of this document?\n7 A. G Fashion Hold Co. B Limited.\n8 MR. FINKEL: Scroll down a bit.\n9 Q. Who signed this document?\n10 A. Mr. He.\n11 MR. FINKEL: Zoom out of that, please. If you could\n12 scroll up.\n13 Q. And can you read 1.1.\n14 A. \"The company's wholly owned parent, Jovial Century\n15 International Limited, issued a capital contribution of\n16 $2,300,000 USD to the company on August 30, 2021.\"\n17 Q. What's Jovial Century International Limited?\n18 A. Among the org chart, it's a higher level above G Club\n19 Operations.\n20 Q. And what were you told, if anything, about who the ultimate\n21 beneficial owner is of Jovial?\n22 A. I don't recall someone telling me.\n23 Q. Did you ask any questions about why G|CLUBS was structured\n24 in this manner, with Jovial at the top?\n25 A. Not that I recall.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 MR. FINKEL: You can zoom out of that.\n2 Q. And can you read 1.2.\n3 A. \"The Sole Director has deemed it to be in the best interest\n4 of the Company to acquire a Bering 70 vessel with Hull ID\n5 Number:\"\n6 Q. That's fine. You don't have to read that.\n7 What's the price?\n8 A. $2,130,000.\n9 Q. And did that money come from a loan from G|CLUBS\n10 Operations?\n11 A. Best of my recollection, yes.\n12 Q. And where did G Club Operations get that $2,130,000 from?\n13 A. Our member——member payment.\n14 Q. Member payments?\n15 A. Yes.\n16 MR. FINKEL: Could we zoom out of that, please. Can\n17 you scroll down.\n18 Keep going.\n19 Q. Can you read what it says at the top, on the right.\n20 A. Yacht Contract.\n21 MR. FINKEL: Zoom out of that, please, Ms. Loftus.\n22 Q. Who signed that contract?\n23 A. Mr. He.\n24 MR. FINKEL: You can take that down.\n25 Q. Did there come a time, if ever, when you spoke to Miles Guo\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 about the yacht?\n2 A. Yes.\n3 Q. What was the name of the yacht?\n4 A. Liberty.\n5 Q. When did you speak with Miles Guo about the Liberty?\n6 A. I'm not exactly sure the date, but some point in 2022.\n7 Q. Was it after the boat was purchased?\n8 A. Could I see the date?\n9 Q. Sure.\n10 A. Sorry.\n11 MR. FINKEL: If you can pull back up, Ms. Loftus,\n12 GC309.\n13 Q. Do you see the date on this email?\n14 A. Yes.\n15 Q. You spoke with Guo about the yacht after it was purchased.\n16 A. Yes.\n17 Q. And what manner did you speak with Guo about the yacht?\n18 A. It was conversation about the boat having some——some\n19 issues, some mechanical issues.\n20 THE COURT: What form of communication was used?\n21 THE WITNESS: Physical, physical. It was in person.\n22 It was a meeting.\n23 Q. Where did this meeting take place?\n24 A. In the New York offices.\n25 MR. FINKEL: You can take that down, Ms. Loftus.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. Who else was part of the meeting?\n2 A. As of my recollection, it was the captain, in a video Zoom,\n3 Yvette, Max. Those are the ones I remember.\n4 Q. Why did you participate in this meeting with Guo, Yvette,\n5 Max, and the boat captain?\n6 A. I was requested to attend the meeting.\n7 Q. Who requested?\n8 A. Best of my recollection, Yvette.\n9 Q. What did Guo say about the yacht?\n10 A. They were talking mechanical aspects, about not being,\n11 like, safe because of——it had like a hole on the front.\n12 Q. Guo was saying these things about the hole in the front?\n13 A. It was conversations between the captain and him, but——I\n14 don't remember specifically.\n15 Q. Did Guo explain how he knew that the yacht had problems\n16 during the call?\n17 A. Not that I recall.\n18 Q. Were G|CLUBS members able to use the Liberty?\n19 A. Not that I was aware.\n20 Q. Was there any process in place to allow G|CLUBS members to\n21 rent the Liberty?\n22 A. No.\n23 Q. Did you ever see the Liberty in person?\n24 A. Yes.\n25 Q. Where?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. In the marina.\n2 Q. Which marina?\n3 A. I don't know the name.\n4 Q. What state?\n5 A. New Jersey.\n6 Q. Why did you see the Liberty yacht in a marina in New\n7 Jersey? Why were you there?\n8 A. After the——the meeting, I wanted to see what the issue was,\n9 so I went to physically see the——the hole and not having, like,\n10 a barrier.\n11 Q. What happened to the Liberty yacht?\n12 A. It ultimately got sold.\n13 Q. Why did you decide to sell the Liberty yacht?\n14 A. I did not decide to sell the boat.\n15 Q. Who decided to sell the boat?\n16 A. To the best of my recollection, that Mr. He decided on it.\n17 Q. Did you ask Mr. He why he wanted to sell the boat?\n18 A. What I was told is that because it was not safe, it wasn't\n19 seaworthy.\n20 Q. Did there come a time, if ever, when G|CLUBS purchased a\n21 camper van?\n22 A. Yes.\n23 Q. How did you learn about this, the camper van?\n24 A. A loan as well.\n25 Q. How did you learn about it?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. It was a request that came in. I'm not exactly sure if it\n2 was Yvette or Mr. He.\n3 Q. Yvette or who?\n4 A. Mr. He.\n5 Q. Did you select the camper van?\n6 A. No, I did not.\n7 Q. Do you know who did?\n8 A. No, I do not.\n9 Q. Do you know how much the camper van cost?\n10 A. I don't recall.\n11 MR. FINKEL: If we could pull up GX GC365.\n12 Q. And what's the subject of this email?\n13 A. G Club International Limited Resolution. Additional asset\n14 purchase.\n15 Q. And was the camper van purchased in the same manner, with a\n16 loan from G|CLUBS Operations to BVI?\n17 A. To the best of my recollection, yes.\n18 Q. And the money that G|CLUBS Operations sent to BVI, where\n19 did that money come from?\n20 A. Membership fees.\n21 MR. FINKEL: Zoom out of that, please.\n22 Go to the next page.\n23 Keep going. Stop right there.\n24 Q. Can you read the English in the second line at the top.\n25 Right there.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. \"Binding order of a new motor vehicle/trailer.\"\n2 MR. FINKEL: Zoom out of that.\n3 Q. And what's the price on the bottom right?\n4 A. 343,235.29.\n5 Q. Who signed that document?\n6 A. Mr. He.\n7 MR. FINKEL: Zoom out of that.\n8 Q. And what's the name of the company at the top?\n9 A. SOD, Stone Off Road.\n10 Q. Where was the camper van manufactured, to your knowledge?\n11 A. Germany, if I'm not mistaken.\n12 Q. Was the camper van ever delivered?\n13 A. Not that I was aware of.\n14 MR. FINKEL: You can take that down.\n15 We can pull up what's been marked for identification\n16 as GC551.\n17 Q. Who is this email from and to?\n18 A. From Pablo to me.\n19 MR. FINKEL: The government offers GC551.\n20 MR. KAMARAJU: No objection.\n21 THE COURT: It is admitted.\n22 (Government's Exhibit GC551 received in evidence)\n23 MR. FINKEL: Could we publish that, please.\n24 BY MR. FINKEL:\n25 Q. And who's Pablo?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Pablo is an attorney.\n2 Q. And who's copied on this email from Pablo to you?\n3 A. Victor.\n4 Q. Victor who?\n5 A. Cerda.\n6 Q. What's the subject of this email?\n7 A. G Club subpoena.\n8 Q. What's the date?\n9 A. June 13, 2022.\n10 MR. FINKEL: Zoom out of that, please. Can you zoom\n11 in on the bottom.\n12 Q. Who is this email from?\n13 A. Juliana Murray.\n14 Q. And what is the text of this email?\n15 A. Sorry?\n16 Q. What is the text of the email, the content? Starting with\n17 Pablo, could you read it.\n18 A. Yes. \"Thank you for agreeing to accept service of the\n19 attached subpoena on behalf of your client, G Club Operations\n20 LLC. Please let us know if you have any questions.\"\n21 MR. FINKEL: You can zoom out of that.\n22 Q. Did you become aware that G|CLUBS received a subpoena on\n23 June 13, 2022?\n24 A. Yes.\n25 Q. At the time, Ms. Reyes, you first learned about this, did\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 you know what a subpoena was?\n2 A. No.\n3 Q. What did you come to understand the subpoena was?\n4 A. It was a——an inquiry from the government for different\n5 charges.\n6 Q. How did you feel learning that G|CLUBS had received the\n7 subpoena from the government?\n8 A. I didn't——I didn't know what——what that was, and I was\n9 concerned because it involved the government.\n10 Q. You said you were what?\n11 A. Concerned.\n12 Q. Did you discuss the subpoena with Ana?\n13 A. At some point, yes.\n14 Q. Did Ana come to leave G|CLUBS?\n15 A. Yes.\n16 Q. When approximately did she leave?\n17 A. September 2022.\n18 Q. What is your understanding of why Ana left?\n19 MR. KAMARAJU: Objection.\n20 THE COURT: Overruled. You may answer.\n21 A. When she presented her resignation letter, she said that\n22 she had found another job, that it was to happen, and at some\n23 point she was concerned with her license being revoked.\n24 Q. What do you mean by concerned about her license being\n25 revoked?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Like her——like her lawyer license.\n2 Q. Around the time that G|CLUBS received the subpoena from the\n3 government, did you have your own lawyer?\n4 A. No, I did not.\n5 Q. Did you ask for one?\n6 A. At some point I did, yes.\n7 Q. Who did you ask for one?\n8 A. To the best of my recollection, counsel.\n9 Q. What were you told about whether you could have your own\n10 lawyer?\n11 A. I was told that I did not need it and if they believed I\n12 did, they would let me know.\n13 Q. How did that make you feel that you weren't being provided\n14 your own lawyer?\n15 MR. KAMARAJU: Objection. Misstates testimony.\n16 THE COURT: You may say how you felt.\n17 A. Not considered, because I was asking for it.\n18 Q. What do you mean by not considered?\n19 A. Like they were not really thinking of me, even though I was\n20 asking for it.\n21 THE COURT: Keep your voice up, please.\n22 THE WITNESS: Sorry.\n23 Q. Ms. Reyes, after G|CLUBS received the subpoena, did you\n24 meet with Miles Guo?\n25 A. In person? I believe so.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. Where?\n2 A. In the New York office.\n3 Q. Have you ever been to the Sherry-Netherland?\n4 A. Yes.\n5 Q. And why did you go to the Sherry-Netherland?\n6 A. It was to have dinner.\n7 Q. With who?\n8 A. Mr. Guo, Alex, and Yvette.\n9 Q. Was this after the subpoena was received by G|CLUBS?\n10 A. Yes.\n11 Q. What did Miles Guo tell you during that dinner?\n12 A. It was like a thank-you dinner for the job that we were\n13 doing in——in G|CLUBS, and during the conversations he asked\n14 about my family, personal information, and there was a\n15 conversation along the lines of, like, his brother being killed\n16 because of his political views and how that meant that he was,\n17 like, trustworthy or true to his——to his beliefs.\n18 Q. Is that the only time you had dinner with Miles Guo?\n19 A. Yes.\n20 Q. Did Miles Guo during that dinner mention anything about\n21 loyalty?\n22 A. Yes.\n23 Q. What did he say about loyalty?\n24 A. It was referencing how——like how his brother was loyal to\n25 his beliefs and he died because of it.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. And what?\n2 A. He died because of it.\n3 Q. And this conversation about loyalty, this was after G|CLUBS\n4 received the subpoena?\n5 MR. KAMARAJU: Asked and answered, your Honor.\n6 THE COURT: Sustained.\n7 MR. FINKEL: I see it's 11:30. Is this a good time to\n8 break?\n9 THE COURT: Although it's 11:30, since we started\n10 late, we'll go until noon, then we'll break. Well, we'll come\n11 back at 12:30, we'll break at 2:30 again.\n12 Go ahead.\n13 MR. FINKEL: Okay. Thank you, your Honor.\n14 We can take that down, Ms. Loftus.\n15 BY MR. FINKEL:\n16 Q. Did there come a time where G|CLUBS sued Crane?\n17 A. Yes.\n18 Q. And what role did you have, if any, as CEO of G|CLUBS, in\n19 deciding to sue Crane?\n20 A. I did not have a role.\n21 Q. Have you ever participated in a phone call with Miles Guo\n22 about Crane's money?\n23 A. Not that I recall.\n24 Q. After G|CLUBS sued Crane, was there an arbitration\n25 proceeding?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Yes.\n2 Q. And at that time did you have your own lawyer?\n3 A. No, I did not.\n4 Q. Were you asked to testify at that arbitration proceeding?\n5 A. Yes.\n6 Q. Did you want to?\n7 A. No.\n8 Q. Did you say you didn't want to?\n9 A. Yes.\n10 Q. What were you told?\n11 A. That because I was the CEO, I had to.\n12 Q. How did that make you feel?\n13 A. Uneasy. I wasn't comfortable doing so.\n14 Q. Generally speaking, at the time of this arbitration\n15 proceeding how were you feeling about G|CLUBS?\n16 A. I was feeling concerned, stressed; there were many things I\n17 didn't understand.\n18 Q. Did you testify at the arbitration proceeding?\n19 A. Yes.\n20 Q. Were you told to say anything in particular at the\n21 arbitration proceeding?\n22 A. What was I going to be talking about?\n23 Q. In advance of the arbitration proceeding, were you told to\n24 say anything in particular during the arbitration?\n25 A. No.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. Did you go into the arbitration proceeding with an\n2 intention to lie?\n3 A. No.\n4 Q. Were you completely truthful with the arbitration panel?\n5 A. There were things that were inaccurate.\n6 Q. What was inaccurate in your testimony?\n7 A. To the best of my recollection, as I referenced Yvette,\n8 Mr. Guo, I did not include him as part of promoting G|CLUBS.\n9 And concierge service. Those are the things I can remember.\n10 Q. How did you describe Yvette during the arbitration\n11 proceeding when you were testifying?\n12 A. As a representative.\n13 Q. And was this arbitration testimony under oath?\n14 A. Yes.\n15 Q. Was Yvette just a representative?\n16 A. That's how I've heard her being described, but she\n17 instructed and——advice on other things.\n18 Q. You also said something about concierge service?\n19 A. Yes.\n20 Q. What did you tell the arbitration panel about concierge\n21 services?\n22 A. Being——having a concierge service. That's how it was\n23 called. But it's more of a customer service.\n24 Q. So when you said that there was a concierge service to the\n25 arbitration panel, was that true?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. No.\n2 Q. You also mentioned that——you mentioned something about Guo\n3 during the arbitration testimony. What did you say that wasn't\n4 correct about Guo?\n5 A. I didn't include him as the promotion of G|CLUBS.\n6 Q. Was Guo involved in the promotion of G|CLUBS?\n7 A. Yes.\n8 Q. When you told the panel that he wasn't involved, or you\n9 didn't say to the panel that he was involved in the promotion\n10 of G|CLUBS, was that true?\n11 A. That was inaccurate.\n12 Q. Did G|CLUBS prevail in the Crane arbitration?\n13 A. Sorry? Could you say that again.\n14 Q. Did G|CLUBS win the Crane arbitration?\n15 A. I'm not sure.\n16 MR. FINKEL: If we can pull up GX GC377.\n17 Q. Who is this email from?\n18 A. From me.\n19 Q. To who?\n20 A. Mr. He.\n21 Q. And what's it in regards to?\n22 A. G|CLUBS loan documents and resolution for Hamilton digital\n23 assets.\n24 Q. What's Hamilton digital assets?\n25 A. I'm not exactly sure.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. And these documents that you attached, sending to Mr. He,\n2 what was the purpose of these documents?\n3 A. They were loan documents and resolutions.\n4 Q. For what?\n5 A. For this case in particular, invest proceeds in the\n6 Hamilton Digital Assets.\n7 Q. What role did you have, if any, in deciding whether to\n8 invest G|CLUBS' funds into Hamilton Digital Assets?\n9 A. I did not have a role.\n10 Q. What was your understanding——well, withdrawn.\n11 Did you ask Mr. He why G|CLUBS funds were being\n12 invested into Hamilton Digital Assets?\n13 A. Not that I recall.\n14 Q. Did you ask Yvette?\n15 A. Not that I recall.\n16 Q. Can you read No. 2 and 3 in your email.\n17 A. G Club International Limited BVI resolution consent to the\n18 adoption of the company to request a loan of 60 million from G\n19 Club Operations.\n20 G Club International Limited BVI resolution II.\n21 Consent to, approves and authorize investment of\n22 $460,549,275.17 in Hamilton Digital Assets.\n23 Q. And can you read the asterisk where it says, \"Please note\"\n24 at the bottom.\n25 A. \"Please note: The 13,450,724.83 difference is considered\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 as a buffer to cover any additional asset purchase/investments\n2 for the remaining of the year.\"\n3 Q. What is your understanding of why that $46,549,275.17 is so\n4 specific?\n5 A. I do not know.\n6 MR. FINKEL: You can zoom out of that, please, and can\n7 we go to the next page.\n8 Q. And can you read where it says \"WHEREAS.\"\n9 A. \"WHEREAS, Sole Member has deemed it to be in the best\n10 interest of the company to loan 60 million USD at 2.2 APR to\n11 the Sole Member, under the terms and conditions further\n12 stipulated in the loan agreement attached here to as Exhibit\n13 A.\"\n14 MR. FINKEL: Zoom out of that. And if we can scroll\n15 down.\n16 Scroll more. And can you zoom in on paragraph 1,\n17 please, Ms. Loftus.\n18 Q. And can you read the first, 1.1.\n19 A. \"The Sole Director and the Company are interested in\n20 investing 46,549,275.17 proceeds in Hamilton Digital Assets\n21 FDSP.\n22 MR. FINKEL: Could we zoom out of that.\n23 Q. And who's indicated as the sole director at the bottom?\n24 A. Mr. He.\n25 MR. FINKEL: If we can pull up GX GC497, which is in\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 evidence, I believe.\n2 Q. Who is this document addressed to?\n3 A. G Club Operations, me.\n4 Q. And what?\n5 A. Me.\n6 Q. And what's Lawall & Mitchell?\n7 A. It's a law firm that we had retained.\n8 MR. FINKEL: You don't need to zoom in on that right\n9 now. Thank you.\n10 Q. What lawyer worked at Lawall & Mitchell that G|CLUBS\n11 interacted with?\n12 A. Aaron.\n13 Q. Who decided to hire Aaron of Lawall & Mitchell for G|CLUBS?\n14 A. To the best of my recollection, it was Victor that took\n15 care of this.\n16 Q. Victor Cerda?\n17 A. Yes.\n18 Q. Did you play any role in deciding to hire Aaron Mitchell?\n19 A. No, I did not.\n20 Q. Can you read the first paragraph, \"As you are aware.\"\n21 A. \"As you are aware, on or about September 29, 2021, G Club\n22 Operations LLC retained Lawall & Mitchell LLC to advise and\n23 represent G Club with respect to its dispute with Crane\n24 Advisory Group, LLC.\"\n25 Q. Keep going, please. Can you read the next paragraph.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. \"In connection with the above referenced arbitration, the\n2 arbitrator directed Crane Advisory Group to transfer certain\n3 funds to G Club. To facilitate the transfer, on or about the\n4 dates below, I received into my escrow account the following 11\n5 wire transfers totaling $46,549,275.17.\"\n6 Q. What is your understanding to mean in the letter where it\n7 says \"I received into my escrow account the following 11 wire\n8 transfers\"?\n9 A. He had an escrow account and the funds were received there.\n10 Q. Funds from Crane?\n11 A. Yes.\n12 Q. And what's your understanding, if any, as to why Aaron\n13 Mitchell received the funds from Crane?\n14 A. He was the attorney on Crane, and there was a request to\n15 have an escrow account, and his firm was the escrow.\n16 MR. FINKEL: Zoom out of that, please.\n17 Scroll down.\n18 And can you blow up the \"On November 8\" paragraph.\n19 Yeah.\n20 Q. Can you read that, please, Ms. Reyes.\n21 A. \"On November 8, 2021, upon the direction of G Club, I\n22 transferred the above sums, totaling $46,549,275.17 from my\n23 attorney escrow account to Hamilton Digital Assets Fund SP;\n24 IMAD——\"\n25 Q. You don't have to read that number.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Ms. Reyes, did you provide the direction to Aaron\n2 Mitchell to transfer the above sums totaling $46 million and\n3 change to Hamilton Digital Assets?\n4 A. No, I did not.\n5 Q. Do you know who did?\n6 A. I'm not sure.\n7 Q. Were you consulted about whether transferring the $46½\n8 million to Hamilton Digital Assets was a good idea for G|CLUBS?\n9 A. Not that I recall.\n10 Q. Did you have a view one way or the other when you were the\n11 CEO whether transferring $46½ million to Hamilton Digital\n12 Assets was a good idea for G|CLUBS?\n13 A. No, I did not.\n14 MR. FINKEL: You can take that down.\n15 If we can pull up GX GC380.\n16 No. 380, please. Sorry.\n17 Actually, Ms. Loftus, can you put that on the left\n18 side of the screen.\n19 And can you zoom in on the top email.\n20 BY MR. FINKEL:\n21 Q. Who is this email from?\n22 A. From Alex.\n23 Q. Are you copied on it?\n24 A. Yes.\n25 Q. Who is it to?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. David Fallon.\n2 Q. Who is David Fallon?\n3 A. David Fallon was amongst the Himalaya Exchange employees.\n4 Q. And what did Alex write to David? Can you read it?\n5 A. \"Good morning, David. Please accept this email as\n6 confirmation that we wish to increase our subscription amount\n7 to our Hamilton PE Fund SP in the amount of $46,549,275.17.\n8 Q. That's good. You can stop there.\n9 Ms. Reyes, did you participate in any discussions\n10 about whether or not to increase G|CLUBS subscription amount in\n11 Hamilton PE Fund?\n12 A. Not that I recall.\n13 MR. FINKEL: Can you zoom out of that, please.\n14 Can you scroll down.\n15 Stop right there.\n16 Actually, if you can go up just a little bit,\n17 Ms. Loftus. Yup.\n18 Q. And can you read what David Fallon wrote on November 9,\n19 2021.\n20 A. \"Morning Alex, I see a credit of the below amount into the\n21 fund bank account. For the fund admin records can you please\n22 provide the following:\n23 \"Proof of the relationship with Lawall & Mitchell LLC\n24 for this transfer.\n25 \"Our fund administrator will need to know that the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 money sent through the law firm is G|CLUBS.\n2 \"Also a confirmation email of the subscription\n3 increase amount. So you are increasing your subscription in\n4 Hamilton Digital Assets SP.\"\n5 Q. And below that is an image, and it says \"Description:\n6 Incoming money transfer. Did I read that right?\n7 A. Yes.\n8 Q. And what's it say below that, after the——\n9 THE COURT: Could you blow that up.\n10 Oh, is there a problem on the screen?\n11 You need to go to the bathroom? Okay. So we'll take\n12 a break. Take a break and we'll come back, ten minutes.\n13 MR. FINKEL: Is this good for a lunch break now or——\n14 THE COURT: Well, actually, now I see that it is\n15 11:45. So we'll break now and return at 12:30.\n16 Do not discuss this case with anyone or amongst\n17 yourselves. Don't permit anyone to discuss the case in your\n18 presence. Do not read, listen, or watch anything from any\n19 source which touches upon the subject matter of this case.\n20 (Jury not present)\n21 THE COURT: You may step out of the courtroom.\n22 Remember not to discuss your testimony.\n23 (Witness not present)\n24 THE COURT: You may be seated.\n25 Is there anything from either party before we return?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 MR. KAMARAJU: Not from the defense, your Honor.\n2 MR. FINKEL: Just a logistical issue that the\n3 government and defense are discussing. I just want to flag it\n4 for the Court. There's no need for the Court to intervene at\n5 this point, as the parties are still discussing, but our next\n6 witness is a FBI analyst. She has an appointment on Thursday\n7 morning that she cannot move. But she'll be available Thursday\n8 afternoon. We noticed the defense that this FBI analyst would\n9 be next——well, next after Ms. Reyes. And so it seems,\n10 depending on the timing of when Ms. Reyes is done, it's\n11 possible that that witness would still be on the stand at the\n12 end of the day and would not be able to return on Thursday\n13 morning, would have to come back to finish their testimony. So\n14 we could either do that, if your Honor is okay with it and the\n15 defense is okay with it——the government has no preference——or\n16 we can just call the witness after, which is a banker from\n17 Morgan Stanley.\n18 THE COURT: Are you saying call the witness Thursday\n19 afternoon?\n20 MR. FINKEL: So the analyst, if we don't finish her\n21 today, she wouldn't be able to finish her testimony on Thursday\n22 morning, so she could come back on Thursday afternoon to\n23 complete her testimony, so it would be out of order in that\n24 sense.\n25 THE COURT: Understood. That's fine with the Court.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 MR. FINKEL: Okay. So the parties will discuss and\n2 advise the Court.\n3 THE COURT: Thank you.\n4 MR. FINKEL: Thank you, your Honor.\n5 (Luncheon recess)\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 AFTERNOON SESSION\n2 12:31 p.m.\n3 (Jury not present)\n4 THE COURT: Would you get the witness, please.\n5 MR. FINKEL: Your Honor, just for our own planning\n6 purpose, will the afternoon break be shorter to make up for the\n7 time for the longer break this morning or will it be the same\n8 30 minute?\n9 THE COURT: Are you making a request?\n10 MR. FINKEL: Yes. We would request a slightly shorter\n11 break to make up for the lost time.\n12 THE COURT: That's fine.\n13 MR. FINKEL: Thank you.\n14 THE COURT: Please get the jurors.\n15 THE LAW CLERK: Jury entering.\n16 (Jury present)\n17 THE COURT: Please be seated. Ms. Reyes, remember\n18 you're still under oath. You may continue the inquiry.\n19 MR. FINKEL: Thank you, your Honor.\n20 BY MR. FINKEL:\n21 Q. Ms. Loftus, could you publish GC-380. I believe we had\n22 this document up before we broke for lunch. And you can zoom\n23 in, Ms. Loftus, on the image.\n24 What does it say below money transfer, Ms. Reyes?\n25 A. Original Lawall & Mitchell.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. And on the right side of the screen, Ms. Loftus, can you\n2 bring up GXZ-12 at page 19. Ms. Loftus, can you zoom in on the\n3 credit amount on the left side of the screen.\n4 The document on the right side of your screen,\n5 Ms. Reyes, Z-12, have you seen that document before?\n6 A. No.\n7 Q. Can you read the number next to the arrow between Lawall &\n8 Mitchell, LLC, and Hamilton Opportunity Fund SPC?\n9 A. 46,549,275.\n10 Q. Is that the same number as the number on the left side of\n11 the screen?\n12 A. Yes.\n13 Q. And can you read the number between Hamilton Opportunity\n14 Fund SP, the middle box, and Hamilton Opportunity Fund SP the\n15 lower box?\n16 A. 46,549,275.\n17 Q. We can take that down. If we can pull up GC-433.\n18 This is an email from June 21, 2021; is that correct?\n19 A. Yes.\n20 Q. And who did you send this email to?\n21 A. Mr. He.\n22 Q. Can you read what you wrote beginning with thank you.\n23 A. Thank you for the signed documents. Please find attach\n24 fully executed loan agreement for your records. We've\n25 submitted the wire transfer request. The 50 million will be\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 sent in two separate as described below. Fire wire 35 million\n2 on Monday.\n3 THE COURT: Could you highlight what is being read\n4 because I can't read such small print. Go ahead.\n5 A. Today June 21, 2021. Second wire. 15 million on\n6 Wednesday, June 23, 2021. Should you have any questions or\n7 doubts do not hesitate to reach me.\n8 Q. If you scroll down, Ms. Loftus. What does that say?\n9 A. It's a loan agreement.\n10 Q. Between who?\n11 A. G/Club Operations and G/Club International Limited.\n12 Q. And G/Clubs Operations is located where?\n13 A. Puerto Rico.\n14 Q. And International Limited is located where?\n15 A. BVI.\n16 Q. Do you recognize the initials at the bottom of the\n17 document?\n18 A. Yes.\n19 Q. Whose are they?\n20 A. Mr. He and mine.\n21 Q. Go the next page please, Ms. Loftus.\n22 What's the date at the top, Ms. Reyes?\n23 A. June 18, 2021.\n24 Q. Zoom out of that please, Ms. Loftus.\n25 And the use of funds at the bottom, can you scroll so\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 we have both pages. Can you read use of funds?\n2 A. The borrower intends to use the loans to increase its\n3 investment into Hamilton Digital Assets FD SP registered in\n4 Cayman Islands and having its registered address at McGrath\n5 Tonner Corporate Services Limited, genesis building, 5th floor,\n6 genesis Close PO Box 446, Grand Cayman KYI 1106, Cayman\n7 Islands. For efficiency purposes, the borrower has requested\n8 lender to send the loan proceeds directly to fund receiver on\n9 its behalf.\n10 Q. Have you been to that location in the Cayman Islands, the\n11 PO Box?\n12 A. No, I have not.\n13 Q. Zoom out of that please and scroll up. And under one,\n14 who's the lender?\n15 A. G/Clubs Operations LLC.\n16 Q. And the borrower is BVI?\n17 A. Yes.\n18 Q. Zoom out of that, please.\n19 And under two, who's the fund receiver under two use\n20 of funds?\n21 A. Should I read it?\n22 Q. Who's the fund receiver under number two?\n23 A. Hamilton Digital Assets FD SP.\n24 Q. In this case G/Club Operations sent the money directly to\n25 Hamilton; is that right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. I don't recollect exactly, but that's what it says.\n2 Q. To your knowledge was there ever any repayment made to\n3 G/Club Operation?\n4 A. Not that I recall.\n5 Q. We can take that down. If we can put up what's in evidence\n6 as GXGC-198. Who is this an email from?\n7 A. Could you repeat that.\n8 Q. Who is this an email from?\n9 A. Mr. He.\n10 Q. And who did he send it to?\n11 A. To me.\n12 Q. Can you read what Mr. He wrote below hope you well?\n13 A. Since our projects in London are doing well, would like to\n14 ask the rest amount of loan agreement to be transferred to\n15 Fiesta Property Developments Limited. Loan agreement is 10\n16 million GBP. We have received 10M USD so far. Once amount has\n17 been confirmed, account will be provided.\n18 Q. Ms. Reyes, what is Fiesta Property Developments LTD?\n19 A. I don't know.\n20 Q. What projects are doing well in London? Do you have an\n21 understanding what that means?\n22 A. I do not know.\n23 Q. And 10 million GBP, do you know what GBP means?\n24 A. British pounds.\n25 Q. If we can pull up what's been marked for identification as\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 GXGC-544 just for the witness, please, Ms. Loftus. You can\n2 scroll to the end of that.\n3 Do you recognize that signature?\n4 A. Yes.\n5 Q. Whose is it?\n6 A. Mr. He's.\n7 Q. Could you scroll up, please. Do you recognize that\n8 signature?\n9 A. Yes.\n10 Q. Whose is it?\n11 A. Zee.\n12 MR. FINKEL: The government offers GC-544.\n13 MR. KAMARAJU: Can I ask one voir dire question, your\n14 Honor?\n15 THE COURT: Go ahead.\n16 MR. KAMARAJU: Prior to meeting with the government,\n17 Ms. Reyes, had you ever seen this document before?\n18 THE WITNESS: No, I had not.\n19 MR. KAMARAJU: Objection.\n20 THE COURT: Go ahead.\n21 (Government's Exhibit GC-544 received in evidence)\n22 BY MR. FINKEL:\n23 Q. If you could publish that, please, Ms. Loftus, and go to\n24 the first page.\n25 What does this say on this document?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Facility agreement.\n2 Q. Keep going.\n3 A. Between G/Club Operations LLC and Jovial Century\n4 International Limited and Fiesta Property Developments LTD.\n5 Q. Can you go to the next page, Ms. Ms. Loftus.\n6 Can you read what it says below facility?\n7 A. The lender hereby agrees to lend the borrower an amount not\n8 exceeding 10 million GBP.\n9 Q. Who's the lender according to this document?\n10 A. G/Club Operations, LLC.\n11 Q. And who's the borrower?\n12 A. Jovial Century International Limited.\n13 Q. And who's the fund receiver?\n14 A. Fiesta Property Developments LTD.\n15 MR. FINKEL: Approaching the witness with a binder.\n16 Q. Ms. Reyes, can you flip through that binder, please.\n17 Ms. Reyes, have you reviewed the documents in that\n18 binder previously?\n19 A. Yes.\n20 Q. Did you select which documents ended up in that binder?\n21 A. No, I did not.\n22 Q. Who signed the documents in that binder?\n23 A. Mr. He.\n24 MR. FINKEL: Your Honor, I'll represent that binder\n25 contains GX1GC-519, 523, 524, 529, 535, 349, 373, 177. The\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 government offers those documents.\n2 MR. KAMARAJU: One moment of voir dire, your Honor.\n3 THE COURT: Go ahead.\n4 BY MR. KAMARAJU:\n5 Q. Ms. Reyes, prior to meeting with the government, had you\n6 ever seen those documents before, the ones that are in the\n7 binder Mr. Finkel just handed you?\n8 A. I have seen the format of the documents. I don't recall\n9 all of them.\n10 Q. The specific documents that he showed you, have you seen\n11 those before?\n12 A. I don't recall all of them specifically.\n13 Q. And besides recognizing the signature on that document, do\n14 you recognize those documents at all?\n15 A. I recognize the format of the documents.\n16 Q. But not the documents themselves, right?\n17 A. Not necessarily all of them.\n18 MR. KAMARAJU: Same objection.\n19 THE COURT: Which ones do you recognize? You said not\n20 all of them, and my question is which ones do you recognize?\n21 THE WITNESS: I don't necessarily remember all of\n22 them.\n23 THE COURT: If you'll step up, please.\n24 (Continued on next page)\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 (At the sidebar)\n2 THE COURT: So if it's just the format and the\n3 signatures, but she can't recognize the documents, I'll have to\n4 revoke my admitting of the ones that we just admitted, and I\n5 wouldn't let the others come in.\n6 MR. FINKEL: Your Honor, under 901(b)(2) and (b)(4)\n7 which allows authenticity subject to recognition of a signature\n8 and also distinctive characteristics of a document, I think the\n9 requirement has met the threshold requirement for authenticity\n10 for a few reasons: These documents which your Honor is free to\n11 take a look at are the same distinctive formatting, and in fact\n12 she's familiar with the general formatting of other documents\n13 that have come into evidence without objection. These are\n14 materials that on their face are from entities that are\n15 involved in this case that are all signed by Mr. He. She has\n16 recognized and authenticated that signature. In addition,\n17 these materials I can represent to the Court were produced by\n18 G/Clubs to the government. They are Bates stamped with G/Clubs\n19 Bates stamps on them. That's another factor that the Court can\n20 take into consideration.\n21 THE COURT: They are Bate stamped?\n22 MR. FINKEL: Yes. I have some case law if the Court\n23 would like. Judge Engelmayer in 2012 in a civil case, but\n24 applying Rule 901 ruled, a district court has broad discretion\n25 over the admissibility of evidence. This is 890 F. Supp. 2nd\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 278 to 298. The test for authentication under Federal Rule of\n2 Evidence 901 is simply whether a reasonable juror could find\n3 the proffered evidence authentic, citing some cases under Rule\n4 901(a). Under 901(a), \"The bar for authentication of evidence\n5 is not particularly high.\" Citing U.S. v. Ardiglia, Second\n6 Circuit case from 2007, and also a Second Circuit case from\n7 2001. The proponent, continuing from Judge Engelmayer, need\n8 not rule out all possibilities inconsistent with authenticity\n9 which are proved beyond any doubt that evidence is what it\n10 purports to be, citing the Second Circuit again.\n11 Rather, a document may be authenticated based on its\n12 \"appearance, contents, substance internal patterns or other\n13 distinctive characteristics, taken in conjunction with the\n14 circumstances,\" citing Rule 901(b)(4). And circumstantial may\n15 establish authenticity citing several cases. Such evidence can\n16 include a document's appearance and content, and it goes on.\n17 So under that case law, your Honor, which cites the Second\n18 Circuit, I think we certainly met that threshold. And the\n19 preliminary question under Rule 904, it's a preponderance that\n20 the government must show. And as Judge Engelmayer articulated,\n21 it's not a particularly high threshold for authenticity.\n22 There's no evidence to suggest these documents are not\n23 authentic. And so the question is whether they are sufficient\n24 to allow a juror to conclude, and of course the defense is free\n25 to cross-examine about these particular documents and argue\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 whatever they wish to argue about their authenticity, but we\n2 have met our threshold.\n3 THE COURT: I have tremendous admiration for Judge\n4 Engelmayer. He clerked for Justice Marshal. So if you can go\n5 through each of these documents and identify those\n6 characteristics that Judge Engelmayer wrote about so\n7 eloquently, I would consider admitting them. Mr. Kamaraju.\n8 MR. KAMARAJU: Well, I guess I would make a couple of\n9 points, your Honor. First of all, the comment about there's no\n10 evidence suggesting their inauthentic nature misses the point.\n11 They have the burden to supply evidence's authenticity. Two,\n12 none of the case law that Mr. Finkel cited dealt with the\n13 particular question that your Honor ask which was whether you\n14 could consider the Bates number as a question of authenticity.\n15 I don't think there is any case law that supports that\n16 proposition.\n17 THE COURT: I think he just said that there is a case.\n18 MR. KAMARAJU: I didn't hear the one he read.\n19 THE COURT: He's looking for the case.\n20 MR. KAMARAJU: So while he finds that. Three, the\n21 question about whether you can authenticate the document\n22 through a signature. What actually 901 says is that you can\n23 take a non-expert's opinion that handwriting is genuine, right.\n24 So you can authenticate the handwriting, that doesn't mean you\n25 authenticate the entirety of the document. You need to be able\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 to say that's somebody's signature, and I recognize this\n2 document for what it is. Frankly, the best evidence that these\n3 documents do not have distinctive characteristics and the like\n4 is the fact that the government has put in so many of them.\n5 They're not corporate records. I'm not aware of a case that\n6 has found corporate records as being distinctive. In fact,\n7 your Honor kind of dealt a little bit with this issue with the\n8 First Abu Dhabi Bank records where the government made a\n9 similar argument with respect to authenticity. And your Honor\n10 said, well just because they look like bank records, doesn't\n11 make them authentic. It doesn't satisfy the authentication\n12 part. The fact that like we say G/Club sole forum, that's not\n13 sufficiently distinctive under -- and I'll try to remember my\n14 case law. But I don't think that's sufficiently distinctive\n15 under any Second Circuit case law, and I'm not sure Mr. Finkel\n16 has cited one that says it is.\n17 MS. SHROFF: May I just have the Judge Engelmayer cite\n18 so I can look it up.\n19 MR. FINKEL: It's 890 F. Supp 278. To your Honor's\n20 first question. Judge -- it's actually a District of\n21 Connecticut case, Faulkner v. Arista Records. It's SDNY,\n22 excuse me. 797 F. Supp. 2d. 299. I'm not certain. I think\n23 it's Judge Preska. I could be wrong about that. In any event,\n24 the court reviewed that all the documents were Bate stamp with\n25 a particular prefix as part of its analysis.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 To respond directly to what defense counsel just said.\n2 I want to make a few points. The first is, that's true. The\n3 question about whether a signature is authentic can be\n4 determined by a witness. And Ms. Reyes has determined that\n5 she's familiar with Mr. He's signature. That all of these\n6 documents are signed by Mr. He. That is direct evidence of\n7 authenticity that Mr. He personally signed those documents\n8 based on what the witness said. There are other\n9 circumstances -- I submit that in and of itself is sufficient\n10 for authenticity. When your Honor ruled with respect to the\n11 First Abu Dhabi records was about 807 hearsay, which is to say\n12 that they can come in for its truth. That's a different\n13 inquiry. It's not relevant here. We did not have a custodial\n14 witness or any witness who can look at the First Abu Dhabi bank\n15 records and say Mr. He signed them. Ms. Reyes did that.\n16 The second piece of circumstantial and direct evidence\n17 that shows their authenticity again, just a threshold showing,\n18 is that these documents look just like the documents, very\n19 similar in format, in fact Ms. Reyes said so, to the other loan\n20 agreement. The third circumstance, your Honor, is that, yes,\n21 I'm saying as an officer of the court they were provided to the\n22 government from G/Clubs, and they have a G/Club Bates stamp.\n23 That is another fact. The fourth circumstance is the content\n24 of the document itself, which your Honor is free to review and\n25 look at, and the contents of those documents concerns loans and\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 other factors that this witness and other witnesses have\n2 testified about that are relevant to the proceeding further\n3 corroborating again the bear threshold finding of authenticity.\n4 And so while the government has the burden, it's a\n5 preponderance, and it's fair for your Honor to evaluate what\n6 suggests they are not authentic. And I've heard no evidence\n7 suggesting that, so they should be admitted.\n8 MR. KAMARAJU: I want to respond to a couple of points\n9 before your Honor rules. First of all, just for a point of\n10 clarification, the argument that we made with respect to the\n11 First Abu Dhabi bank account was both authenticity and the\n12 residual exception. And your Honor found that it couldn't be\n13 authenticated or admitted under the rule exception. That's\n14 point one. Point two, I would be curious if the Faulkner case\n15 that Mr. Finkel has cited is actually about admission of\n16 evidence into the trial record, or admission with respect to a\n17 motion, cause I think those are different standards. Three, I\n18 would say that the fact that somebody recognizes handwriting is\n19 sufficient to authenticate the document is signed by that\n20 person. It is not sufficient to authenticate the substance of\n21 the document, i.e., I can show that Ms. Shroff signed a letter.\n22 I can't say further that that letter is a letter that went to\n23 the Court or that letter is one that went to the probation.\n24 All I can say is I recognize Ms. Shroff's handwriting on that.\n25 Third, the distinctive characteristics. If they want\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 to go through and have her identify what's distinctive, okay,\n2 maybe she can do it. But otherwise, I think what she answered\n3 is, I recognize generally the format.\n4 MR. FINKEL: If I could just respond to that. The\n5 witness could do that, but she doesn't have to. Your Honor is\n6 the fact finder here and makes the preliminary ruling, and\n7 you're free, your Honor, to review the documents and compare\n8 them to the other documents that have been admitted. With\n9 respect to Judge Engelmayer's opinion, I'm not certain whether\n10 it was about a trial or not --\n11 MR. KAMARAJU: I was talking about Faulkner.\n12 MR. FINKEL: Judge Engelmayer's opinion analyzed Rule\n13 901. Rule 901 is the same regardless of the circumstances.\n14 Second just to quote from another SDNY opinion. I'm sorry I\n15 don't have the judge. Another civil case, but again same rule,\n16 901. A finding of authenticity \"may be based entirely on\n17 circumstantial evidence.\" Citing the Second Circuit U.S. v.\n18 Bagaric, 706 F. 2d. 42. That's from 1983. One of the\n19 circumstances is that she identified the signature. There are\n20 other circumstances which I've already listed. Putting them\n21 altogether we have passed, I certainly believe, the place where\n22 a reasonable juror could find the proffer of evidence\n23 authentic. That's all that needs to be satisfied. They're\n24 free to cross-examine her on the document. They're free to\n25 make arguments about the document, but we've met our threshold\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 for the finding.\n2 MS. SHROFF: Your Honor, I would like the cites, and\n3 it's really unfortunate that this wasn't -- we didn't have any\n4 notice. So if you could just send me the case cites that\n5 you've recited. I will step out and look at them. But I'm\n6 pretty sure Judge Engelmayer case was in the civil context.\n7 MR. FINKEL: It is a civil case.\n8 MS. SHROFF: And I believe that the requirements would\n9 be different in a criminal case versus a civil trial.\n10 MR. FINKEL: There's no difference between Rule 901 in\n11 a civil case and a criminal trial. To the extent there's a\n12 confrontation clause issue, which maybe what you're alluding\n13 to, the witness is on the stand, and you can cross-examine her\n14 about the signature on the documents.\n15 THE COURT: So did you go through the signature on\n16 each of the documents that you wanted to admit?\n17 MR. FINKEL: Yes, we can certainly do that. They're\n18 all signed by Mr. He.\n19 THE COURT: I think you have to do that, and I think\n20 you have to ask whether the format is consistent with other\n21 documents that the corporation used. On that basis, I would\n22 find them admissible.\n23 MS. SHROFF: Could I have the cites, please.\n24 (Continued on next page)\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 (In open court; jury present)\n2 MR. KAMARAJU: Your Honor, just a point of\n3 clarification. Does the ruling at the sidebar apply to the\n4 exhibit you previously admitted or just what's in the binder?\n5 THE COURT: The ruling at the sidebar applies to the\n6 admission of the first document as well as the ones that\n7 follow. The government is going to go through each document.\n8 BY MR. FINKEL:\n9 Q. Ms. Reyes, can you take a look at the binder. On each\n10 particular document, can you let the jury know if you recognize\n11 any signatures on the document?\n12 A. I recognize the signature on all the document.\n13 Q. Whose signature do you recognize on every single document?\n14 A. Mr. He.\n15 Q. You mentioned I think in response to defense counsel's\n16 questions that the format I think you said familiar or\n17 something like that. Can you describe what you mean?\n18 A. When loan documents were created, it included a said\n19 package and resolutions were made as well, and the format of\n20 the resolutions is like the ones that are here.\n21 MR. FINKEL: Government offers GX GC-519, 523, 524,\n22 529 535, 349, 373 and 177.\n23 THE COURT: They are admitted.\n24 (Government's Exhibits GC-519, GC-523, GC-524, GC-529\n25 GC-535, GC-349, GC-373 and GC-177 received in evidence)\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 BY MR. FINKEL:\n2 Q. If we can please put up for the witness GXGC-544.\n3 You can go to last page, Ms. Loftus. Second to last\n4 page. Ms. Reyes, do you recognize any signature on this page?\n5 A. Yes.\n6 Q. Whose signature is that?\n7 A. Mr. He.\n8 Q. Can you go back a page.\n9 Whose signature is on page 14 of this document?\n10 A. Zee.\n11 Q. Can you scroll up, please. In your time at G/Clubs, did\n12 you see documents where the lender was G/Clubs Operations?\n13 A. Yes.\n14 MR. FINKEL: Your Honor, the government offers GC-544.\n15 MR. KAMARAJU: I maintain my objection, your Honor.\n16 THE COURT: It is admitted.\n17 (Government's Exhibit GC-544 received in evidence)\n18 BY MR. FINKEL:\n19 Q. You can take that down. Ms. Loftus, if you can put up for\n20 identification GC-515 just for the witness.\n21 Do you recognize the signature on this document?\n22 A. Yes.\n23 Q. Whose signature is it?\n24 A. Mr. He.\n25 MR. FINKEL: The government offers GXGC-515.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 MR. KAMARAJU: We make the same objection, your Honor.\n2 THE COURT: It is admitted.\n3 (Government's Exhibit GC-515 received in evidence)\n4 BY MR. FINKEL:\n5 Q. Can we publish that. What's the amount of the transfer\n6 indicated on this document?\n7 A. There are two transfers. One is 20 million and the other\n8 one is 15 million.\n9 Q. We can take that down. If you can put up what's been\n10 marked for identification just for the witness, please,\n11 Ms. Loftus, GXGC-378.\n12 Ms. Reyes, who is this an email from?\n13 A. Mr. He.\n14 Q. And who received it?\n15 A. Me.\n16 MR. FINKEL: Government offers GC-378.\n17 MR. KAMARAJU: No objection.\n18 THE COURT: It is admitted.\n19 (Government's Exhibit GC-378 received in evidence)\n20 BY MR. FINKEL:\n21 Q. We can take that down. And one more if we could put up\n22 GC-232.\n23 Ms. Reyes, who is this an email from?\n24 A. Me.\n25 Q. And who's it to?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Mr. He.\n2 MR. FINKEL: Government offers GC-232.\n3 MR. KAMARAJU: No objection.\n4 THE COURT: It is admitted.\n5 (Government's Exhibit GC-232 received in evidence)\n6 BY MR. FINKEL:\n7 Q. We can take that down. If you could put up GXGC-552 for\n8 identification just for the witness.\n9 Ms. Reyes, did you receive this email dated October\n10 17, 2022?\n11 A. Yes.\n12 MR. FINKEL: Government offers GXGC-552.\n13 MR. KAMARAJU: No objection.\n14 THE COURT: It is admitted.\n15 (Government's Exhibit GC-552 received in evidence)\n16 BY MR. FINKEL:\n17 Q. If we can publish that, please.\n18 Who is Manuel?\n19 A. Manuel is an attorney for G/Clubs.\n20 Q. And who's copied on this email on October 17, 2022. Sorry,\n21 who is it to?\n22 A. Victor and me.\n23 Q. Victor who?\n24 A. Cerda.\n25 Q. What's the attachment on this email? Can you read that?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Mercantile Bank Seizure Warrant.\n2 Q. Did there come a time, Ms. Reyes, when you learned that\n3 G/Clubs' funds were seized by the government?\n4 A. Yes.\n5 Q. Zoom out of that please, Ms. Loftus. Can you zoom into the\n6 bottom email. Who is this email from?\n7 A. Juliana Murray.\n8 Q. Who is it sent to?\n9 A. Manuel Pietrantoni.\n10 Q. Can you read the text of it.\n11 A. Mr. Pietrantoni, the attached seizure warrant which was\n12 served yesterday provides for the freezing of G/Club's account\n13 at Mercantile Bank pending the transmission of the funds in\n14 that account which are subject to seizure and forfeiture to the\n15 United States. My colleagues and I are available if you have\n16 any questions.\n17 Q. You can zoom out of that. Go to the next page.\n18 Can you read what it says right below that box?\n19 A. Warrant of seizure.\n20 Q. What does it say at the top left?\n21 A. United States District Court Southern District of New York.\n22 Q. Zoom out of that, and can you scroll down, please,\n23 Ms. Loftus. Can you go to paragraph A.\n24 Can you read paragraph A, Ms. Reyes?\n25 A. All monies contained in Mercantile Bank International\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Account MVI10103000 held by G/Clubs International Limited and\n2 all funds traceable thereto including accrued interest.\n3 Q. Ms. Reyes, what reaction did you have, if any, when you\n4 learned that the U.S. government had seized G/Clubs funds held\n5 at Mercantile bank?\n6 A. I was concerned because it involved the government and\n7 that's not to be taken lightly.\n8 Q. Can you scroll to the top, please, Ms. Loftus.\n9 What's the date of this email in which you learned\n10 about the seizure?\n11 A. October 17, 2022.\n12 Q. We can take that down, and if you can put up for the\n13 witness GXGC-41.\n14 Who is this email from?\n15 A. Mr. He.\n16 Q. Who did he send it to?\n17 A. Me and Alex.\n18 MR. FINKEL: Government offers GC-41.\n19 MR. KAMARAJU: No objection.\n20 THE COURT: It is admitted.\n21 (Government's Exhibit GC-41 received in evidence)\n22 BY MR. FINKEL:\n23 Q. Can you publish it, please.\n24 Ms. Reyes, do you remember this email?\n25 A. Yes, I do.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. What do you remember about it?\n2 A. I remember receiving the email, and I felt that I was not\n3 being valued at the time. I felt it was a harsh difficult\n4 email to receive.\n5 Q. What's the date of this email?\n6 A. October 18, 2022.\n7 Q. That's the date after the seizure warrant email?\n8 A. Yes.\n9 Q. What do you mean you didn't feel valued?\n10 A. I've been working very hard to create the benefits for the\n11 members and setting up the team and working for the business to\n12 the best of my abilities. And reading those types of comments\n13 made me feel that it's just like if it didn't matter.\n14 Q. Can you read the first two sentences of the email?\n15 A. I am extremely disappointed about Limarie not replying to\n16 my messages and emails. I have no idea what kind of CEO she\n17 is. She acts as if she's the owner of this business which is\n18 complete non-sense. From now we must cancel all her signatory\n19 rights and wait for my further instruction.\n20 Q. What happened that caused you to receive this email,\n21 Ms. Reyes?\n22 MR. KAMARAJU: Objection to form.\n23 THE COURT: Did something happen?\n24 Q. Did something happen prior to you receiving this email?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. What?\n2 A. It was asked for us to send some funds to the bank and the\n3 recommendation from legal was not to do so and that related to\n4 the email.\n5 Q. Who did you convey the recommendation from legal not to\n6 transfer the funds to?\n7 A. To the best of my recollection Yvette or Mr. He.\n8 Q. And after you conveyed that, you received this email?\n9 A. To the best of my recollection yes.\n10 THE COURT: I did not hear what you said.\n11 A. To the best of my recollection yes.\n12 THE COURT: And who is HHR?\n13 THE WITNESS: Mr. He.\n14 Q. I'm going to ask you to speak into the microphone so\n15 everyone can hear you. Thank you.\n16 After the paragraph in which Mr. He said that he was\n17 extremely disappointed, can you read what he wrote for\n18 secondly?\n19 A. Secondly, going back to business, we must maintain our bank\n20 relationships so we are asked to send some funds to the\n21 accounts, so please do the following. Five million to K Bank\n22 ASAP. Five million to Black Thorn after my further\n23 instructions. Do keep me updated on the progress and I need to\n24 see progress not unanswered messages or emails.\n25 Q. What did you understand that to mean when Mr. He said I\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 need to see progress?\n2 A. That he wanted things to get done.\n3 Q. Were you not answering his emails?\n4 A. Around the time, no.\n5 Q. Why not?\n6 A. Because I was working on legal matters that we had\n7 received.\n8 Q. Which legal matters are you referring to?\n9 A. The seizure.\n10 Q. Did you ask for your own attorneys at the time of the\n11 seizure?\n12 A. I don't recall exactly, but I did ask for my attorneys.\n13 Q. If we can pull up what's in evidence as GXGC-43/\n14 THE COURT: Who was O'Neil & Jorge representing?\n15 THE WITNESS: I'm sorry.\n16 THE COURT: Pietrantoni, who was he representing?\n17 THE WITNESS: G/Clubs.\n18 THE COURT: Go ahead.\n19 BY MR. FINKEL:\n20 Q. Did you have a personal lawyer that represented you,\n21 Limarie Reyes, at that time?\n22 A. No, I did not.\n23 Q. First just to orient us, Ms. Loftus, if you can zoom in on\n24 the bottom email. Ms. Reyes, is that the email we just looked\n25 at?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. Yes.\n2 Q. Did you respond to that?\n3 A. Yes.\n4 Q. Zoom out of that, please, and scroll up.\n5 Can you read what you wrote in response?\n6 A. Yes. Dear, Mr. He, hope this message finds you well. My\n7 sincerest apologies for the lack of communication during past\n8 days. I've been handling a few legal issues that have taken my\n9 full attention. Among those legal issues, please find the\n10 below box link including copy of the recent seizure warrant to\n11 G/Club International Limited, BVI. Please note we are\n12 currently looking for an attorney to represent BVI and will\n13 keep you updated during this process. Under no circumstance my\n14 intention has been to act as the owner of the business.\n15 On the contrary, I deeply respect you as my superior\n16 and any action taken by me has been carefully carried out\n17 taking into consideration the best interest of the company. To\n18 this point, I respect your decision to cancel all my signatory\n19 rights and will act accordingly. Regarding G/Club banking\n20 relationship, please note that while no action has been taken\n21 towards G/Club Operations, in light of the recent circumstances\n22 with BVI transferring funds out of the existing accounts to\n23 fund foreign accounts could provoke the U.S. authorities to\n24 cease G/Club Operations U.S. accounts. Nevertheless, please\n25 confirm that you wish to proceed in funding the accounts as\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 stated below. I've attached the wire instructions for both\n2 accounts. SKB Bank and Black Thorn for your confirmation as\n3 the correct wiring instructions.\n4 Q. Was this a difficult time for you at G/Clubs?\n5 A. Yes.\n6 Q. Do you believe that you ever took an action to consider\n7 yourself as the owner of G/Clubs?\n8 A. No.\n9 Q. You can zoom out of that. Can we scroll down.\n10 What is this document?\n11 A. The wiring instruction details.\n12 Q. Where did Mr. He want you to wire this money after the\n13 seizure warrant?\n14 A. The wire instruction say Kyrgyz Swiss bank.\n15 Q. Ms. Reyes, after the legal department recommended not to do\n16 this wire, Mr. He told you to do it. Did this wire go through?\n17 A. Yes.\n18 Q. Take that down.\n19 Did there come a time G/Clubs tried to get the money\n20 that was seized back from the U.S. government?\n21 A. Could you say that again.\n22 Q. Did there come a time, if ever, when G/Clubs tried to get\n23 the money back from the U.S. government, the money that was\n24 seized?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. What were you asked to do, if anything, as part of that\n2 litigation?\n3 A. I was asked to sign an affidavit.\n4 Q. Can you please speak into the mic.\n5 Did you have your own attorneys at this time?\n6 A. No, I did not.\n7 Q. Did you want to sign the affidavit?\n8 A. No, I did not.\n9 Q. Did you write the affidavit?\n10 A. No, I did not.\n11 Q. Did you express your concern that you didn't want to sign\n12 this affidavit?\n13 A. Yes.\n14 Q. What were you told?\n15 A. That I was the CO and that I had to sign it.\n16 Q. I'm sorry.\n17 A. I had to sign it.\n18 Q. Did you sign the affidavit?\n19 A. Yes, I did.\n20 Q. Is everything in the affidavit completely truthful?\n21 A. Not everything.\n22 Q. What are some things in the affidavit that weren't\n23 truthful?\n24 A. I don't remember the full content on top of my mind, how I\n25 describe travel, concierge service, and how I describe the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 community.\n2 Q. Did you consider leaving G/Clubs around this time?\n3 A. Yes.\n4 Q. Did you ultimately leave G/Clubs?\n5 A. Yes.\n6 Q. When?\n7 A. When, March 2023.\n8 Q. Why?\n9 A. At that time many legal issues going on. There had been\n10 arrests. I had concerns. And by that time I had my personal\n11 lawyers.\n12 Q. Did you get a personal lawyer after Miles Guo was arrested?\n13 A. Yes.\n14 Q. Looking back on it, do you feel that Mr. He valued your\n15 contributions, if any, at G/Club?\n16 A. I'm not sure. It didn't feel like it.\n17 Q. It did not feel like it?\n18 A. Yeah.\n19 Q. Ms. Reyes, after the seizure in October of 2022, did you\n20 travel again to Europe?\n21 A. Yes.\n22 Q. Who asked you to go to Europe?\n23 A. Yvette.\n24 Q. How much notice did you have before you traveled to Europe?\n25 A. Not much notice.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. How much?\n2 A. Couple of days.\n3 Q. What were you told by Yvette as to why you had to go to\n4 Europe?\n5 A. We were to meet with the banks for them to get to know us\n6 and us to get to know them.\n7 Q. Where in Europe did you go?\n8 A. I'm sorry.\n9 Q. Where in Europe did you go?\n10 A. Switzerland.\n11 Q. Had you been to Switzerland before?\n12 A. No.\n13 Q. How did you travel there? What mode of transportation?\n14 A. Plane.\n15 Q. Commercial or private?\n16 A. Commercial.\n17 Q. Did you travel with anyone?\n18 A. Alex.\n19 Q. Who did you meet in Switzerland if anybody?\n20 A. Mr. He, some attorneys and representative of the bank.\n21 Q. Was there a meeting with a representative of the bank?\n22 A. Yes.\n23 Q. What bank?\n24 A. mBear.\n25 Q. Can you spell that?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 A. M-B-A-E-R if I'm not mistaken.\n2 Q. What was your understanding of the purpose of this meeting\n3 with mBear?\n4 A. It was to meet with the bank, for them to get to know us\n5 and us to get to know them.\n6 Q. What did Mr. He say, if anything, about G/Clubs during this\n7 meeting with mBear?\n8 A. During the meeting, during that meeting, we had to talk\n9 about the benefits and explain some like financial as to how\n10 members are referencing bank statements.\n11 Q. When did this meeting occur? Do you know the month?\n12 A. November 2022.\n13 Q. What did you talk about in the meeting, which topic?\n14 A. The benefits.\n15 Q. What did Alex talk about?\n16 A. Finances.\n17 Q. What did Mr. He talk about?\n18 A. He interjected in the meeting and he explain how G/Clubs\n19 was his idea and how it came to be.\n20 Q. Did Mr. He after mentioning that G/Clubs was his idea and\n21 how it came to be, did he say anything about how Guo got\n22 involved?\n23 A. To the best of my recollection, he mention Guo as his\n24 person of interest.\n25 Q. Did he provide any detail about how Guo became the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 spokesperson?\n2 A. I don't recall specifically.\n3 Q. If we can put up what's in evidence as GXGC-438.\n4 Can you read this?\n5 A. It's a loan agreement between G/Club International Limited\n6 and Mileson.\n7 Q. And who?\n8 A. Mileson.\n9 Q. What does the document say, and who does it say Mileson is\n10 on the document?\n11 A. Qiang Guo.\n12 Q. And you know that name as Mileson?\n13 A. That's what I was told.\n14 Q. Scroll down, please. Who's the lender?\n15 A. G/Club International Limited.\n16 Q. And the borrower?\n17 A. Qiang Guo.\n18 Q. And can you read the second Whereas clause?\n19 A. Whereas subject to the terms of this agreement lender will\n20 loan 10 million to borrower.\n21 Q. If we could pull up what's in evidence as GXGC-416.\n22 And who's this email from?\n23 A. Mr. He.\n24 Q. To who?\n25 A. To me.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. What does it say?\n2 A. Hi, Limarie, bank account details attached.\n3 Q. Go to the next page.\n4 Who is this account in the name of at the bottom of\n5 your screen?\n6 A. Qiang Guo.\n7 Q. Can we look at GXGC-415.\n8 What's the date of this email?\n9 A. January 14, 2022.\n10 Q. Can you read it.\n11 A. Hi, Limarie. We have green light from Mr. Guo bank for the\n12 loan. Please prepare the transaction today, and I will come\n13 back with and details. We have to change the currency to Swiss\n14 Frank as this is the request from them. We must make sure we\n15 don't have a bad rate if we do this.\n16 Q. Did Mr. He explain why they wanted to change the currency\n17 to Swiss Frank?\n18 A. Not that I recall.\n19 Q. Did you ask him why?\n20 A. I don't remember.\n21 Q. Did you ask Mr. He why there was a loan being made to\n22 Mileson?\n23 A. Not that I recall.\n24 Q. Did you ask Yvette?\n25 A. Not that I recall.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO2 Reyes - Direct\n1 Q. Did you have any role in the decision to loan money to\n2 Mileson?\n3 A. No, I did not.\n4 Q. Can you pull up GXGC-418.\n5 Who is this document from?\n6 A. From me.\n7 Q. Who's it to?\n8 A. Mr. He.\n9 Q. And what did you attach to this document?\n10 A. Loan agreements.\n11 Q. For which loan?\n12 A. Could you scroll it a bit.\n13 Q. Sure. Can we scroll the attachments, Ms. Loftus.\n14 A. It's a loan to Qiang Guo.\n15 Q. The next page, please. We can take that down.\n16 Ms. Reyes, do you know if the loan to Mileson was ever\n17 paid back?\n18 A. Not that I recall.\n19 Q. Ms. Loftus, if we can pull up GXC-212. Can you go to one\n20 minute and 35 seconds. Can you play.\n21 (Media played)\n22 Q. Ms. Reyes, when a member bought a membership in G/Clubs,\n23 did they immediately become a shareholder in G/Clubs?\n24 A. No.\n25 MR. FINKEL: Nothing further.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 THE COURT: Cross examination.\n2 CROSS-EXAMINATION\n3 Q. Good afternoon, Ms. Reyes.\n4 A. Good afternoon.\n5 Q. Can you hear me okay?\n6 A. Yes.\n7 Q. Do you need a minute?\n8 A. I'm okay.\n9 Q. Now, I'd like to just start A little bit with the video we\n10 just watched. Okay.\n11 Now, Mr. Guo became a spokesperson for G/Clubs at a\n12 certain point, right?\n13 A. He was the spokesperson for G/Club, yes.\n14 Q. And he was the spokesperson before you got to G/Club,\n15 right?\n16 A. Yes.\n17 Q. And you were introduced to G/Clubs through a recruiter I\n18 believe you testified, right?\n19 A. Recruiter interview me, yes.\n20 Q. And was that Steve Weber?\n21 A. Yes.\n22 Q. And the position that you originally had at the company was\n23 VP in marketing, right?\n24 A. Yes.\n25 Q. And as part of your role, then you had to secure benefits\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 for G/Club members, right?\n2 A. Yes.\n3 Q. And that part of your job at least, securing benefits,\n4 continued throughout your time at G/Clubs, right?\n5 A. Yes.\n6 Q. When you refer to sort of the contribution that you thought\n7 Mr. He had not valued, part of it was the work you had put in\n8 securing benefits, right?\n9 A. The work throughout.\n10 Q. Throughout, through your whole time there?\n11 A. Yes.\n12 Q. And in terms of providing benefits or services, you had a\n13 lot of experience before you got to G/Club doing that kind of\n14 work, right?\n15 A. I had experience in events.\n16 Q. You had almost ten years worth of experience in events\n17 before you got there, right?\n18 A. Yes.\n19 Q. You had worked at a large hotel chain as an event manager,\n20 right?\n21 A. Yes.\n22 Q. You were the director of member services at a premier golf\n23 club in Puerto Rico, right?\n24 A. Yes.\n25 Q. You had worked at for planning events at something called\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 Invest Puerto Rico, right?\n2 A. Yes.\n3 Q. What's Invest Puerto Rico?\n4 A. It's a company that brings new business to Puerto Rico.\n5 Q. And you were in charge of planning their events, right?\n6 A. Yes.\n7 Q. And now you run your own event planning business, right?\n8 A. Yes.\n9 Q. And Mr. Finkel asked you some questions about that, right?\n10 A. Yes.\n11 Q. It's called Sprinkle; is that right?\n12 A. Sprinkle events.\n13 Q. And you just started that in November, right?\n14 A. Yes.\n15 Q. So a little over six months ago?\n16 A. Yes, around that time.\n17 Q. So you're just getting started, right?\n18 A. Yes.\n19 Q. And when you joined G/Club, it was also just getting\n20 started, right?\n21 A. Yes, that was my understanding.\n22 Q. There weren't a whole lot of employees, right?\n23 A. No.\n24 Q. You were employee number one in the Puerto Rico office?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 Q. And there were some employees in New York, right?\n2 A. There's some people in New York, yes.\n3 Q. But still not very many, right?\n4 A. There was just a few people.\n5 Q. Do you remember how many there were when you started?\n6 A. Not exact amount.\n7 Q. Under five?\n8 A. Doing a rough count.\n9 Q. Totally fine.\n10 A. A little bit over five.\n11 Q. And when you first joined G/Clubs, you understood that the\n12 primary audience for the company's offering was Chinese, right?\n13 A. Yes.\n14 Q. And in particular it was a specific group of Chinese people\n15 who were opposed to the Chinese Communist Party?\n16 A. Could you repeat that.\n17 Q. The people who you understood would be particularly\n18 attracted to G/Clubs offerings were Chinese people who were\n19 opposed to the Chinese Communist Party, right?\n20 A. Yes.\n21 Q. And Ms. Wang told you that during the first interview?\n22 A. I do not recall specifically.\n23 Q. But over the course of your time at G/Club, you came to\n24 understand that, right?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 Q. I think you testified on direct that you don't personally\n2 have a lot of experience with the Chinese community, right?\n3 A. Yes.\n4 Q. And you don't personally have a lot of knowledge about\n5 Chinese politics, right?\n6 A. Yes.\n7 Q. And you don't personally have a lot of knowledge about\n8 Chinese culture, right?\n9 A. No, I do not.\n10 Q. It's not the culture you grew up in, right?\n11 A. No.\n12 Q. Now, Mr. Guo is part of that community, right?\n13 A. Which community?\n14 Q. Well, the Chinese anti-CCP community, let's just start\n15 there?\n16 MR. FINKEL: Objection.\n17 THE COURT: If you would be more specific if you\n18 could.\n19 Q. You understand Mr. Guo is Chinese, right?\n20 A. Yes.\n21 Q. And you understand that he is taken an anti-CCP position in\n22 public, correct?\n23 A. Yes.\n24 Q. So his views are similar to the views of G/Clubs' target\n25 audience, correct?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 MR. FINKEL: Objection.\n2 THE COURT: If you happen to know what the view point\n3 is of the audience, you may answer if you know.\n4 A. My understanding is that they're like-minded individuals.\n5 Q. And maybe you can just tell the jury what you mean when you\n6 may \"like-minded?\"\n7 A. That amongst the members, they have a league to be in\n8 opposition of the Chinese government.\n9 Q. Could you say that again.\n10 A. In opposition of the government.\n11 Q. Opposition of the Chinese government. Okay.\n12 Now, it made sense to you that Mr. Guo would be a\n13 spokesperson for G/Clubs, right?\n14 A. He was the spokesperson for G/Club.\n15 Q. Sure, but that didn't strike you as odd, right?\n16 A. That's how it was when I came in.\n17 Q. I understand. I'm asking you a slightly different\n18 question, Ms. Reyes.\n19 My question is, did it strike you as strange to have\n20 Mr. Guo as the spokesperson?\n21 MR. FINKEL: Objection.\n22 THE COURT: You may answer.\n23 A. Can you repeat the question.\n24 Q. Did it strike you as strange that Mr. Guo would be working\n25 as the spokesperson for G/Club?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 A. I understood he was in the opposition, so I don't think so.\n2 Q. And when you say he was in a position, he was in a position\n3 to attract potential G/Club members, right?\n4 A. Sorry, he was in opposition of the Chinese government.\n5 Q. I'm sorry. He was in opposition to the Chinese government,\n6 and so that made sense that he would be a spokesperson to\n7 G/Club. Is that what you were saying?\n8 A. Yes.\n9 Q. Now, you testified on direct that he didn't receive any\n10 monetary compensation for that role, right?\n11 A. Not that I was aware of.\n12 Q. Now, part of G/Clubs' marketing was access to affluent life\n13 experiences, right?\n14 A. I'm sorry.\n15 THE COURT: Mr. Kamaraju, if you would please get\n16 closer to the microphone so we could hear you.\n17 Q. Part of G/Clubs' marketing was sort of marketing life\n18 experiences, right?\n19 A. Benefits, we offer benefits.\n20 Q. But some of those benefits, for example, you looked at a\n21 website yesterday with Mr. Finkel. You remember that?\n22 A. Yes.\n23 Q. And some of those benefits curated life experiences, right?\n24 A. What do you mean by \"curated?\"\n25 Q. Let me give you a specific example.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 G/Clubs had entered into an engagement with the F-1\n2 Racing Association, correct?\n3 A. We had offered a benefit with F-1 yes.\n4 Q. And the idea there was to give G/Club members the\n5 opportunity to experience an F-1 race, right?\n6 A. Yes.\n7 Q. That's what I mean by a life experience or curated life\n8 experience. Okay. Are we on the same page?\n9 A. Yes.\n10 Q. And that was sort of G/Club's business model, right?\n11 MR. FINKEL: Your Honor, I object to defense counsel\n12 defining terms different from how Ms. Reyes may understand\n13 them.\n14 THE COURT: You may answer the question.\n15 A. Could you repeat the question.\n16 Q. Sure. I was just saying part of G/Club's business was\n17 offering those kinds of experiences, right?\n18 A. To offer different benefit for the members, yes.\n19 Q. Now, those benefits included things like luxury hotel\n20 deals, right?\n21 A. Yes.\n22 Q. Potential trips on yachts, right?\n23 A. Yes.\n24 Q. There were membership summits, right?\n25 A. What do you mean by summits? G Talks.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 Q. Sure. G Talks. There was discounts on G Fashion?\n2 A. Yes.\n3 Q. And you were pursuing other benefits during the course of\n4 your employment there, correct?\n5 A. Yes.\n6 Q. You tried to get a Super Bowl event at some point, right?\n7 A. A what, sorry?\n8 Q. An event for somebody to go to the Super Bowl?\n9 A. Not that I recall.\n10 Q. We'll come back to that.\n11 Now, in addition to those benefits, you understood\n12 that one of the things that G/Club members got was the ability\n13 to say they were part of the club, right?\n14 A. They were part of the membership club.\n15 Q. Right. So there was a social affinity that the members\n16 could feel, right?\n17 A. What do you mean like social affinity?\n18 Q. I'm trying to go back to your idea of like-minded group of\n19 people. There were people that were united by sort of a common\n20 purpose?\n21 A. They were like-minded, yes.\n22 Q. And having G/Club membership was one way of demonstrating\n23 that, right?\n24 A. Yes, they were among the membership.\n25 Q. And within the potential target audience for G/Clubs, you\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 considered Mr. Guo to be a bit of a tastemaker, right?\n2 A. What's a tastemaker?\n3 Q. Well, somebody whose perspective on lifestyle might be\n4 valued by G/Clubs members, right?\n5 MR. FINKEL: Object to the form.\n6 THE COURT: Are you asking whether she agrees with\n7 your definition, or are you offering that definition in order\n8 that she answer the question?\n9 MR. KAMARAJU: I was just asking her understanding\n10 I'll try to rephrase it and see if I can do it a different way,\n11 your Honor.\n12 Q. You watch the video on direct of Mr. Guo appearing on like\n13 a yacht, right?\n14 A. Yes.\n15 Q. And you testified about seeing a video where Mr. Guo\n16 showcasing the Lamborghini on behalf of G/Clubs, right?\n17 A. Yes.\n18 Q. And part of the marketing efforts for G/Clubs was to tell\n19 members that they could have those kinds of experiences, right?\n20 A. Like yachts and cars?\n21 Q. Yeah.\n22 A. Right.\n23 Q. And so Mr. Guo to your understanding was living a life like\n24 that, right?\n25 MR. FINKEL: Objection, your Honor, to the form.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 THE COURT: You can answer whether you thought that\n2 Mr. Guo was living a life like that.\n3 A. What's the question? Was that the question, if he's living\n4 a life like that?\n5 Q. That was your understanding?\n6 A. Yes.\n7 Q. And you went to his home for dinner, right?\n8 A. Yes.\n9 Q. It's a very nice house, right?\n10 A. Yes.\n11 Q. It was on the 18th floor of a hotel in Manhattan?\n12 A. I don't remember the floor. It was high.\n13 Q. And I won't ask you which side of Central Park it was on,\n14 but in Manhattan, right?\n15 A. You could see Central Park.\n16 Q. You could see Central Park from it, right. It was a very\n17 large place, right?\n18 A. It was big.\n19 Q. Luxurious, right?\n20 A. Yes.\n21 Q. There's a security desk at the bottom before you could come\n22 upstairs, right?\n23 A. Yes.\n24 Q. The elevator opened right up into the apartment, right?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO3 Reyes - Cross\n1 Q. There are a bunch of rooms, right?\n2 A. There are different rooms.\n3 Q. Mr. Guo took you on a tour of the place, right?\n4 A. Yes.\n5 Q. Did you see any camping equipment when you were there?\n6 A. Camping?\n7 Q. Yes.\n8 A. None that I recall.\n9 Q. Now, you testified that -- what did you consider Mr. Guo's\n10 responsibilities to be as spokesperson for G/Club?\n11 A. He was the spokesperson.\n12 Q. So what's a spokesperson do?\n13 A. Talk on behalf of company.\n14 Q. So they advertise, right?\n15 A. To speak, yeah.\n16 Q. Their role is to try to get business for G/Club?\n17 A. To speak on behalf of the company.\n18 Q. Right. But the purpose of them speaking on behalf of the\n19 company is to bring perspective members to the company, right?\n20 A. It would attract people, yes, to attract people.\n21 Q. G/Club is fundamentally a business, right?\n22 A. Yes.\n23 Q. As a business, it makes money the more members it can\n24 attract, right?\n25 A. It's based on the members.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 BY MR. KAMARAJU:\n2 Q. Right. And the role of advertising, I think you testified\n3 it was word-of-mouth advertising principally for G|CLUBS,\n4 right?\n5 THE COURT: Mr. Kamaraju, you have to get closer to\n6 the microphone; and so do you, Ms. Reyes.\n7 MR. KAMARAJU: Sorry.\n8 Q. Right? You testified on direct that it was word-of-mouth\n9 advertising, principally?\n10 A. I don't recall specifically saying that, but part of it was\n11 word of mouth.\n12 Q. Okay. So whatever form of advertising G|CLUBS was doing,\n13 that was intended to bring potential members to the company,\n14 right?\n15 A. Correct.\n16 Q. And Mr. Guo was part of that effort, right?\n17 A. Spokesperson, yes.\n18 Q. And he made videos as part of that effort, right?\n19 A. I know that he made videos.\n20 Q. Okay. And in those videos——you testified already about at\n21 least one. In those videos, he advertised for G|CLUBS, right?\n22 A. Which specifically? Sorry.\n23 Q. Well, you testified on direct about the one with the\n24 Lamborghini, right?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. And he was talking about the Lamborghini as a benefit for\n2 G|CLUBS, right?\n3 A. Correct.\n4 Q. Okay. So that's him advertising G|CLUBS, right?\n5 A. Talking about future benefits.\n6 Q. Sure. Talking about future benefits that G Club members\n7 could enjoy, right?\n8 A. Those benefits were to be future benefits for——for the\n9 members.\n10 Q. Okay. Now you testified on direct that G|CLUBS had to put\n11 out a disclaimer about Mr. Guo's statements. Do you remember\n12 that?\n13 A. There was a disclaimer.\n14 Q. Okay. I'd like to show you just what's been marked for\n15 identification as DX 60600.\n16 MR. KAMARAJU: And that's just for the witness and the\n17 parties, please.\n18 Q. If you could just take a second to look over that, please.\n19 A. Okay.\n20 Q. Tell me when you're done.\n21 A. Okay.\n22 Q. This is a version of that disclaimer, right?\n23 A. To the best of my recollection, yes.\n24 Q. Okay. And this disclaimer appeared on the website, right?\n25 A. To the best of my recollection, yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 MR. KAMARAJU: Okay. Your Honor, the defense offers\n2 DX 60600.\n3 MR. FINKEL: Provided there's an instruction, no\n4 objection. I'm happy to discuss at sidebar, but——\n5 THE COURT: All right. We'll have a sidebar.\n6 (Continued on next page)\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 (At the sidebar)\n2 MR. FINKEL: I just ask for a limiting instruction.\n3 With the limiting instruction, no objection.\n4 THE COURT: You're saying you want me to tell them\n5 what?\n6 MR. FINKEL: That it's not being offered for its\n7 truth.\n8 MR. KAMARAJU: We're offering it for what G Club\n9 members were being told, so if your Honor wants to instruct\n10 them that it's for the effect on or the impact on the readers,\n11 that's fine, yeah.\n12 MR. FINKEL: Well, given that, actually, I'm not sure\n13 Ms. Reyes can testify as to the impact on the members. She can\n14 testify as to the impact on herself.\n15 MR. KAMARAJU: I'm not saying I'm going to ask her\n16 questions about the impact on the members; I'm just trying to\n17 admit the actual disclaimer, which she can authenticate.\n18 MR. FINKEL: You said for the impact on the members,\n19 no?\n20 MR. KAMARAJU: But that doesn't——\n21 THE COURT: He's trying to introduce it, and using her\n22 to authenticate it. And she's not a member so she couldn't say\n23 what impact it had on her as a member, but she doesn't need to\n24 talk about the impact on members.\n25 MR. FINKEL: Understood. The government would request\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 a limiting instruction, and with that, we have no objection.\n2 THE COURT: Okay.\n3 (Continued on next page)\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 (In open court)\n2 THE COURT: Members of the jury, this document here on\n3 the screen titled Disclaimer, it is not being offered for the\n4 truth of what is written there, what is said there, it's merely\n5 being offered for its impact on those who read it.\n6 Go ahead.\n7 (Defendant's Exhibit 60600 received in evidence)\n8 MR. KAMARAJU: Thank you, your Honor.\n9 Could we publish it for the jury, please.\n10 BY MR. KAMARAJU:\n11 Q. So Ms. Reyes, you said this appeared on the website,\n12 correct?\n13 A. Yes, to the best of my recollection, yes.\n14 Q. Okay. And let's just start at the top. Could you read the\n15 first line, please.\n16 A. \"The concept for G|CLUBS and scope of benefits available to\n17 members has developed over time and may differ from promotional\n18 statements G|CLUBS or others may have made in the past before\n19 you sought to become a member.\"\n20 MR. KAMARAJU: All right. Now let's go down to the\n21 second paragraph, please.\n22 Q. Could you read that.\n23 A. \"You should not rely on any descriptions by Mr. Guo Wengui\n24 or any other person of (i) the benefits that could or would be\n25 available to G|CLUBS' members or (ii) any other aspect of the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 structure or terms of membership in G|CLUBS. Membership is not\n2 an investment in G|CLUBS, nor does it provide an equity or\n3 ownership interest in G|CLUBS or any other entity. G|CLUBS is\n4 not an investment club, nor does it provide investment services\n5 as a membership benefit. If you are seeking to make an\n6 investment in any entity, do not send any funds to G|CLUBS as\n7 G|CLUBS only accepts payment for memberships.\"\n8 MR. KAMARAJU: Just one moment.\n9 Thank you. We can take that down. And I'm going to\n10 ask that we pull up Government Exhibit C160-V and go to the\n11 11:35 mark.\n12 Q. And while that's happening, Ms. Reyes, do you remember on\n13 direct Mr. Finkel asked you some questions about G Fashion\n14 stock, right?\n15 A. Yes.\n16 Q. And questions about the availability of G Fashion stock to\n17 G|CLUBS members, right?\n18 A. Yes.\n19 Q. And you remember he asked you about this portion of this\n20 video?\n21 A. What exactly? Sorry.\n22 Q. Well, I'm happy to play it. We can play a little bit of it\n23 for you.\n24 MR. KAMARAJU: Could we play just a few seconds.\n25 (Video played)\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 MR. KAMARAJU: Pause there.\n2 Q. All right. So you remember Mr. Finkel asked you some\n3 questions about that?\n4 A. I don't remember specifically, but I——\n5 Q. Okay. Do you remember testifying that this comment by\n6 Mr. Guo about receiving G Fashion stocks wasn't true?\n7 A. We did not offer stock.\n8 Q. Okay. G|CLUBS didn't offer the G Fashion stock, right?\n9 A. Correct.\n10 Q. Now you were the CEO of G|CLUBS, not G Fashion, right?\n11 A. Correct.\n12 Q. You didn't have any responsibility for G Fashion, right?\n13 A. No.\n14 Q. So you don't have any reason to know if G Fashion could\n15 offer stock to G Club members, right?\n16 A. I do not know.\n17 Q. Just like a rental company offering benefits through a\n18 frequent flyer mile program, right?\n19 MR. FINKEL: Objection.\n20 THE COURT: Sustained.\n21 Q. And you were never part of any discussions related to that,\n22 right?\n23 A. Not that I recall.\n24 Q. All right. Now do you see the date on this video?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. June 28, 2020, right?\n2 A. Yes.\n3 Q. G|CLUBS hadn't launched by then, right?\n4 A. I'm not sure.\n5 Q. When is the first date you remember G|CLUBS being alive?\n6 A. When I started.\n7 Q. Okay. So that's December of 2020, right?\n8 A. Yes.\n9 MR. KAMARAJU: All right. So now can we pull up\n10 Government Exhibit GX GC541. Should be the consulting\n11 agreement. I think that's in evidence, so we can put it up.\n12 All right. And let's have it up for the jury too,\n13 please. Thank you.\n14 Q. Okay. This is Mr. Guo's consulting agreement with G|CLUBS,\n15 right?\n16 MR. KAMARAJU: Why don't we blow up the first\n17 paragraph under Consulting Agreement.\n18 Q. Do you see that?\n19 A. Yes.\n20 Q. So this is the consulting agreement?\n21 A. Yes.\n22 Q. Okay. And do you see it says something called the\n23 Effective Date, right?\n24 A. Yes.\n25 Q. What's the effective date?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. October 15, 2020.\n2 Q. Okay. So that's after June 28, 2020, right?\n3 A. Yeah.\n4 Q. Okay. So that's after the video that Mr. Finkel showed\n5 you, right?\n6 A. Yes.\n7 MR. KAMARAJU: Now could we pull up Government Exhibit\n8 GX Z9, please. And go to page 57.\n9 Okay. And let's just blow up the date in the top left\n10 corner. And can we highlight it.\n11 Q. Okay. Can you read that date for me.\n12 A. October 13, 2020.\n13 Q. Okay. So it's within two days of the consulting agreement,\n14 right?\n15 A. I don't remember the date. Could we go back. I'm sorry.\n16 Q. Oh, it's okay. We'll move on.\n17 A. Okay.\n18 MR. KAMARAJU: Can we go to page 59 of this. And can\n19 we blow up the text that starts, \"Under the reviewed launch\n20 plan.\"\n21 And maybe we can just highlight that. Well, you know\n22 what? Withdrawn.\n23 Q. Could you just read the text on the screen, please.\n24 A. \"Under the reviewed launch plan for G-Clubs, however,\n25 members will not thereby have opportunity to subscribe for or\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 purchase any shares to be issued in the future, will NOT\n2 receive G-TV stock, and will NOT receive loans to purchase\n3 memberships.\n4 \"This is serious business, brothers and sisters. Even\n5 if you have bought G-Club, it absolutely will not come with the\n6 stocks; it does not mean that you can buy stocks of G-Fashion\n7 and G-TV; and, it does not mean that you will be able to\n8 receive loans in the future. No! No! No!\n9 \"I'll repeat, this is a very serious topic. No! No!\n10 There is no GTV's stock and there is no G-Fashion's stock.\n11 When I hear all this, I got chills. There is none of that.\"\n12 MR. KAMARAJU: Okay. We can take that down. Thank\n13 you.\n14 Q. Now in order to obtain a G Club membership, prospective G\n15 Club members had to fill out an application, right?\n16 A. Yes.\n17 Q. And they did that online?\n18 A. To the best of my understanding, yes.\n19 MR. KAMARAJU: Okay. Could we show just for the\n20 witness and the parties and the Court DX 60601, please.\n21 Q. This is how they would get to the application, correct?\n22 A. I have to take a read.\n23 It looks like one of the steps, amongst the process.\n24 Q. This is one of the click-throughs or whatever.\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 MR. KAMARAJU: The defense would offer DX 60601. Same\n2 basis as the last document, your Honor.\n3 MR. FINKEL: I think we're approaching a point that\n4 your Honor has ruled on previously. If we could be heard at\n5 sidebar. Or not. The government objects.\n6 THE COURT: Are you asking for the limiting\n7 instruction?\n8 MR. FINKEL: No. This is different, your Honor.\n9 But——\n10 THE COURT: If you would please give me a hard copy of\n11 what you're referring to.\n12 What I'm referring to is the hard copy of the document\n13 you're seeking to admit.\n14 MR. FINKEL: Oh, that's the defense.\n15 MR. KAMARAJU: Do we have a copy?\n16 I can move on or we can come back to it, your Honor.\n17 THE COURT: Okay.\n18 BY MR. KAMARAJU:\n19 Q. Now as part of your work at G|CLUBS, you helped with\n20 marketing of the company's products, right?\n21 A. Could you say that again.\n22 Q. Sure. You helped design the marketing of the company's\n23 products, right?\n24 A. What do you mean by the products? The marketing products?\n25 Q. I just mean the services or the benefits that G|CLUBS was\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 selling.\n2 A. The benefits, yes.\n3 Q. You were VP of marketing when you first got there, right?\n4 A. Yes.\n5 Q. And that continued while you were——when you became interim\n6 CEO, right?\n7 A. At some point there was a team.\n8 Q. Okay. Let's talk about that team. At what point did that\n9 team come in?\n10 A. Throughout——throughout time.\n11 Q. Okay. And about how large was that team by the time you\n12 left?\n13 A. Best of my recollection, around 14 employees.\n14 Q. Okay. Were those all marketing people?\n15 A. No.\n16 Q. Okay. So how large was the marketing staff itself?\n17 A. It changed through time. The marketing itself, roughly\n18 around three.\n19 Q. Okay. And what were their responsibilities?\n20 A. Different responsibilities throughout time. Redesign of\n21 the website; designing of gift boxes that we did; reaching out\n22 to partners, potential partners; design of communication\n23 emails.\n24 Q. Okay. Let's start with the website. You never spoke with\n25 Mr. Guo about the website content, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. Not that I recall.\n2 Q. Okay. And you mentioned I think it was communications\n3 emails; is that what you said at the end there?\n4 A. Yes, emails.\n5 Q. So those are communications to the members, right?\n6 A. Yes.\n7 Q. You never spoke with Mr. Guo about what went in those\n8 either, right?\n9 A. Not that I recall.\n10 Q. Okay. And there was a newsletter that went out to G|CLUBS\n11 members, right?\n12 A. Those emails were communicated.\n13 Q. So there were emails where you communicated with them.\n14 A. Yes.\n15 Q. You never asked Mr. Guo for his views on the content of\n16 those, right?\n17 A. Not that I recall.\n18 Q. Okay. Now in terms of what was described on the website,\n19 that was up to you and the marketing team, right?\n20 A. That depends, 'cause there are different phases. When\n21 specifically?\n22 Q. Okay. All the things that Mr. Finkel asked you about\n23 yesterday.\n24 A. I don't remember all. Could you——\n25 Q. Any of them.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. Any of the things that——\n2 Q. That Mr. Finkel asked you about yesterday. Did you bear\n3 responsibility for any of that content?\n4 A. Of the website.\n5 Q. Mm-hmm.\n6 A. Sorry. The question is if I created the content?\n7 Q. Were you responsible for any of the content that Mr. Finkel\n8 asked you about yesterday?\n9 A. The marketing team and I, yes.\n10 Q. Okay. And you did that totally independent of Mr. Guo,\n11 right?\n12 A. We did not ask him.\n13 Q. Okay. So when you described things on the website, that\n14 was the result of your work with the marketing team, right?\n15 A. Yes.\n16 Q. Okay. And when you communicated with members, that was\n17 G|CLUBS' employees' work, right?\n18 MR. FINKEL: Object to the form.\n19 MR. KAMARAJU: Okay. Withdrawn.\n20 Q. There were G|CLUBS employees responsible for putting\n21 together the emails that went out to the members, right?\n22 A. There were different components puts in all the emails,\n23 what went out.\n24 Q. I'm sorry. I couldn't hear you.\n25 A. There were different components in order to put out an\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 email.\n2 Q. Okay. And those components are comprised of G|CLUBS\n3 employees; is that right?\n4 A. Some of them, yes.\n5 Q. Okay. And there are others, right?\n6 A. Yes.\n7 Q. Okay. Who were the others?\n8 A. Copywriters.\n9 Q. Are the copywriters not G|CLUBS employees?\n10 A. Outsourced.\n11 Q. Okay. So there was a third party that was working on that,\n12 right?\n13 A. Some of them, yes.\n14 Q. And the same thing is actually true of the sweepstakes too,\n15 right?\n16 A. What do you mean?\n17 Q. The sweepstakes were administered by third parties, right?\n18 A. The selection of the sweepstakes winner, yes.\n19 Q. And that third-party sweepstakes administrator, that's a\n20 company that you picked, right?\n21 A. There are two, two events. The first one, I did not pick\n22 it; the second one, it was a review amongst the legal team and\n23 myself.\n24 Q. Okay. Not Ms. Wang, right?\n25 A. I'm sorry?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Not Ms. Wang, right?\n2 A. On the second event, no.\n3 Q. Okay. And not Mr. Guo, right?\n4 A. Not that I was made aware of.\n5 Q. Okay. Mr. Guo never spoke to you about a particular\n6 sweepstakes winner at all, right?\n7 A. A particular?\n8 Q. Well, let me try it this way. Mr. Guo never came to you\n9 and said, make sure this person wins the sweepstakes, right?\n10 A. No.\n11 Q. He never came to you and said, make sure this person\n12 doesn't get their sweepstakes prize, right?\n13 A. No.\n14 Q. He never came to you and said, make sure this person gets a\n15 refund, right?\n16 A. No.\n17 Q. He never came to you and said, make sure this person\n18 doesn't get a refund, right?\n19 A. No.\n20 Q. He never came to you and said, this person's a CCP spy so\n21 make sure they don't get anything, right?\n22 A. No.\n23 Q. In fact, you did not communicate with Mr. Guo very often,\n24 did you?\n25 A. I communicated with Mr. Guo a fair amount of times.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. And yet in all those times, he never said any of that to\n2 you, right?\n3 A. Not that I recall, no.\n4 Q. And Mr. Guo never told you what benefits you needed to\n5 offer, right?\n6 A. Not that I recall.\n7 Q. Okay. So he didn't dispatch you to London, right?\n8 A. No.\n9 Q. He didn't tell you to go look for this property or that\n10 property, right?\n11 A. No.\n12 Q. He never told you, go buy me a Bugatti, right?\n13 A. No.\n14 Q. He never said, go buy me a Lamborghini, right?\n15 A. No.\n16 Q. He never said, go buy me a Ferrari, right?\n17 A. No.\n18 Q. He never said, go buy me a camper van, right?\n19 A. No.\n20 Q. He never said, go buy me a boat that has a hole in it, did\n21 he?\n22 A. No.\n23 Q. Mr. Guo never asked you for a single benefit through\n24 G|CLUBS, correct?\n25 A. Not that I recall.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Now you testified on direct that there was an effort at one\n2 point to take Mr. Guo's image off of the website, right?\n3 A. Yes.\n4 Q. And that was because banks had difficulty with the\n5 association between G|CLUBS and Mr. Guo, correct? That was\n6 your understanding?\n7 MR. FINKEL: Objection.\n8 THE COURT: Sustained.\n9 Q. Okay. Did you have an understanding of why Mr. Guo's image\n10 needed to come off the website?\n11 A. I was told that it was making it difficult for banking\n12 relationship that Mr. He was doing.\n13 Q. So at the time your understanding was it was difficult with\n14 banking relationships?\n15 MR. FINKEL: Objection. Misstates the witness's\n16 testimony.\n17 THE COURT: Sustained.\n18 Q. Okay. So at the time what was your understanding?\n19 MR. FINKEL: Objection. Asked and answered.\n20 THE COURT: Sustained. Asked and answered.\n21 Q. Okay. Now at the same time when you took Mr. Guo off the\n22 website, he was still very publicly associated with the\n23 company, right?\n24 A. What do you mean by publicly?\n25 Q. He spoke——he spoke at the G Talk summit, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. Yes.\n2 Q. He made videos, right?\n3 A. The one that I saw.\n4 Q. If you wanted to find out that there was a connection\n5 between Mr. Guo and G|CLUBS, you could do it, right?\n6 MR. FINKEL: Objection.\n7 THE COURT: Overruled. You may answer.\n8 A. Could you repeat the question.\n9 MR. KAMARAJU: I'm sorry. Could we read it back,\n10 please. I don't think I could do it again.\n11 (Record read)\n12 A. What do you mean by \"connection\"?\n13 Q. What's your understanding of the word \"connection\"?\n14 A. Something tied.\n15 Q. Okay. So using that, using that definition, your\n16 understanding of that phrase, can you answer my question from\n17 before.\n18 A. If it was tied or related to G|CLUBS? Yes.\n19 MR. KAMARAJU: Okay. Could we pull up Government\n20 Exhibit GC431, please, which is in evidence.\n21 And we'll pull it up for the jury, please.\n22 Q. Okay. So do you remember this document?\n23 A. Yes.\n24 Q. Okay. And it's an email from you to Mr. He, correct?\n25 A. Correct.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. And it's from June 9, 2021, correct?\n2 A. Correct.\n3 Q. And it's attaching something called the Business Alliance\n4 Presentation, right?\n5 A. G|CLUBS Alliance presentation, yes.\n6 Q. What is that presentation?\n7 A. It's a presentation that talked about——it was a\n8 presentation made for one of the Alliances that we reached out\n9 to.\n10 Q. Okay. And for the jury's benefit, can you tell us what you\n11 mean by the Alliances.\n12 A. Yes. This was the hotel chain, L&R Properties, that was\n13 created for it.\n14 Q. Okay. So you were preparing this to submit to the L&R\n15 chain; is that right?\n16 A. This was a presentation to present to the L&R people.\n17 Q. Okay. And I believe you testified on direct that\n18 that——there was a man named Mr. Ian who was in connection with\n19 that company; is that right?\n20 A. Correct.\n21 Q. What's his last name?\n22 A. I don't remember.\n23 Q. Okay. Robinson, by any chance?\n24 A. I don't recall. It doesn't sound——\n25 Q. Okay. And what was the purpose of sending or designing\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 this presentation?\n2 A. It was a request from Mr. He.\n3 Q. Okay. And this is the presentation that he asked you to\n4 remove Mr. Guo from, right?\n5 A. Best of my recollection, yes.\n6 Q. Okay. And would you describe L&R as a potential partner?\n7 Is that the——I just want to use the right word. Is that the\n8 way you described them?\n9 A. Yes.\n10 Q. Okay. And G|CLUBS had other partners that they were trying\n11 to develop relationships with, right?\n12 A. Correct.\n13 Q. Okay. And at one point G|CLUBS had a partnership with the\n14 US Tennis Association, correct?\n15 A. US Open.\n16 Q. Yes. Yes.\n17 A. Yeah.\n18 Q. Now was that association terminated?\n19 A. The agreement?\n20 Q. Yes.\n21 A. It——it never happened.\n22 Q. Okay. Do you have an understanding of why it didn't\n23 happen?\n24 MR. FINKEL: Objection.\n25 THE COURT: You may answer.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. We received an email; there was some difficulties with the\n2 banks, and the payment.\n3 MR. KAMARAJU: Okay. Can we go down to page 6 of\n4 this, please.\n5 All right. Could we just blow up the text there.\n6 Q. Do you see where it says Target Market?\n7 A. Yes.\n8 Q. Okay. And can you just read what it says under that, that\n9 first sentence.\n10 A. \"High net worth Chinese individuals/families, though\n11 membership is available to everyone.\"\n12 Q. Okay. And then can you keep going to read the rest of it.\n13 A. \"Marketing strategies are undertaken by leveraging the\n14 reach and impact of key spokespeople, strategic partners,\n15 influencers and well-connected individuals in these Chinese\n16 communities.\"\n17 Q. So what did you mean when you wrote \"leveraging the reach\n18 and impact of key spokespeople, strategic partners, influencers\n19 and well connected individuals in these Chinese communities\"?\n20 MR. FINKEL: Objection. I don't think the witness\n21 stated that she wrote that.\n22 THE COURT: You need to first ask whether she wrote\n23 it.\n24 Q. Did you write it?\n25 A. I don't recall writing it.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Okay. Do you know who wrote it?\n2 A. I'm not exactly sure.\n3 Q. All right. When you sent this to Mr. He, did you review it\n4 before sending it?\n5 A. I believe I did.\n6 Q. I'm sorry?\n7 A. I believe I did.\n8 Q. Okay. Did you make any changes to it?\n9 A. There were changes made to the different versions.\n10 Q. Okay. Did you suggest any changes?\n11 A. Not that I recall.\n12 Q. Okay. Was it important to you in sending this to your boss\n13 that it was well done?\n14 A. Yes.\n15 Q. Okay. If there had been mistakes in the presentation, you\n16 would have fixed them, right?\n17 MR. FINKEL: Objection.\n18 THE COURT: You may answer.\n19 A. If requested to do changes, I would have done it.\n20 Q. Okay. But you were communicating directly with Mr. He\n21 about it, right?\n22 A. Correct.\n23 Q. And I think you testified on direct that he could be pretty\n24 abrasive, right?\n25 A. What do you mean abrasive?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. He could be harsh.\n2 A. In instances.\n3 Q. Sure. From time to time, right?\n4 A. There were some instances.\n5 Q. Okay. When he was dissatisfied with something that was\n6 happening, right?\n7 A. There were instances, yes.\n8 Q. Now did you have an understanding of what this phrase\n9 means?\n10 A. I'm not exactly sure.\n11 Q. So you sent it to Mr. He without knowing what it meant?\n12 A. I don't recall.\n13 Q. You don't recall if you sent it to him or——\n14 A. No, no, no. I recall sending it to him.\n15 Q. Okay.\n16 A. I don't recall at the time——\n17 MR. KAMARAJU: Okay. Let's look at page 15 of the\n18 presentation.\n19 And can we blow that up.\n20 Q. Could you read what that says at the top.\n21 A. Physical Clubs.\n22 Q. Okay. And can you read the first sentence, please.\n23 A. \"G|CLUBS anticipates establishing its first club\n24 headquarters in Puerto Rico, with plans to develop physical\n25 clubs around the world.\"\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Okay. Could you read the next one.\n2 A. Members will enjoy club benefits and amenities, including\n3 guest rooms, conferences, ballrooms, restaurants, business\n4 centers, spas, and others.\n5 Q. Okay. Do you have an understanding of what these two\n6 paragraphs mean?\n7 A. It's a——the idea of having physical clubs, ideally, in\n8 Puerto Rico, and later on, throughout the world.\n9 Q. Okay. So G|CLUBS was representing itself to its potential\n10 partners as planning to have physical clubs, right?\n11 A. Yes.\n12 Q. Okay. And do you see where it says, \"The clubs allow\n13 members to safely congregate in luxury with other like-minded\n14 individuals or simply spend quality time with their families\"?\n15 A. Yes.\n16 Q. Do you understand why it says \"safely congregate\"?\n17 A. No, I do not.\n18 Q. Now you testified that there weren't G|CLUBS members in\n19 Puerto Rico, right?\n20 A. Not that I was aware of.\n21 Q. Okay. So why would the first club headquarters be in\n22 Puerto Rico?\n23 A. The thought process, at least our team, was that our\n24 offices were in Puerto Rico and we wanted to make Puerto Rico\n25 their home.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Okay. So in your understanding, G|CLUBS members would\n2 travel from around the world to Puerto Rico to visit this\n3 location, right?\n4 A. As one of them.\n5 Q. Okay. But that was the thought, right?\n6 A. Yes.\n7 Q. And there would be others, right?\n8 A. Ideally, yes.\n9 Q. And you thought about——for example, there was an island\n10 that you were looking at buying, right?\n11 A. Yes, there was an island.\n12 Q. Okay. Now while there weren't G|CLUBS members in Puerto\n13 Rico, you knew that there were G|CLUBS members in New York,\n14 right?\n15 A. Yes.\n16 Q. And there were G|CLUBS members in London, right?\n17 A. Yes.\n18 Q. And there were G|CLUBS members in other parts of Asia,\n19 right?\n20 A. Yes.\n21 Q. And there were G|CLUBS members in Australia, right?\n22 A. Yes.\n23 Q. And there were G|CLUBS members on the West Coast, right?\n24 Of America.\n25 A. Yeah, yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Right? There were G|CLUBS members on the East Coast of\n2 America, right?\n3 A. Different parts.\n4 Q. Okay. Just not Puerto Rico, right?\n5 A. Not that I was aware of.\n6 Q. Now you testified that a big part of your job was trying to\n7 secure benefits, right?\n8 A. Yes.\n9 Q. Oh, sorry. Take your time.\n10 A. No, no. Yes.\n11 Q. And you remember Mr. Finkel asked you questions about the\n12 benefits that G Club members received, right?\n13 A. Yes.\n14 Q. And you listed several of them, right?\n15 A. Yes.\n16 Q. There were luxury hotel benefits you had, right?\n17 A. Yes.\n18 Q. That was a benefit that was secured under your leadership\n19 at G|CLUBS, right?\n20 A. Yes.\n21 Q. There was a yacht brokerage sort of arrangement, correct?\n22 A. Boating company.\n23 Q. Okay. Boating company. That was another benefit that was\n24 secured under your leadership, right?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. There was the Formula One thing that we talked about\n2 before, right?\n3 A. Yes.\n4 Q. Another benefit secured under your leadership, right?\n5 A. Yes.\n6 Q. There was the FAO Schwarz event, right?\n7 A. Yes.\n8 Q. That was another benefit that was secured under your\n9 leadership, right?\n10 A. Yes.\n11 Q. There was hotel stays in Fiji, right?\n12 A. Yes.\n13 Q. Right? That was another benefit that was secured under\n14 your leadership, right?\n15 A. Yes.\n16 Q. There was also a block of rooms available in Australia,\n17 right?\n18 A. There was a stay, yes.\n19 Q. Another benefit, right?\n20 A. Yes.\n21 Q. So those were all benefits that G|CLUBS members had access\n22 to while you were working at the company, right?\n23 A. Yes.\n24 Q. And that's in addition to the G Fashion discount that they\n25 got, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. Yes.\n2 Q. Now on direct, Mr. Finkel asked you some questions about\n3 what G|CLUBS paid to get those benefits. Do you remember that?\n4 A. Yes.\n5 Q. And you said that G|CLUBS had not actually paid any money\n6 to get those benefits, right?\n7 A. Not all of them, some of them.\n8 Q. Okay. So some of them they paid for and some of them they\n9 didn't, right?\n10 A. Yes.\n11 Q. Okay. So let's talk about the ones that they——well, let me\n12 ask you this first. Withdrawn.\n13 Do you remember which ones they paid for?\n14 A. I recall the FAO Schwarz.\n15 Q. Okay. And for the ones that they didn't pay for, those\n16 benefits were offered pursuant to an agreement between G|CLUBS\n17 and the partner, right?\n18 A. There were agreements, yes.\n19 Q. There were contracts, right?\n20 A. Right.\n21 Q. And those contracts provided for certain benefits that the\n22 partner would receive, right?\n23 A. Well, if——could you——\n24 Q. Let me take a step back. Let me try it this way, okay? So\n25 as part of those agreements, the partners agreed to give\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 certain——let's just use the discount example——discounts to\n2 G|CLUBS members, right?\n3 A. Right.\n4 Q. And in exchange for doing that, the partners got something,\n5 right?\n6 A. If it was a hotel, they would get a hotel room night\n7 booked.\n8 Q. Sorry. They would get a hotel night, right? A hotel room\n9 booked, right?\n10 A. Yes.\n11 Q. And other agreements had cross-marketing opportunities,\n12 right?\n13 A. I don't remember specifically.\n14 Q. Well, do you remember an agreement with a yacht company?\n15 A. There was a boating company, yes.\n16 Q. Was that YachtLife?\n17 A. I don't remember the name. Jet Life resonates.\n18 Q. Okay. And part of your agreement, G|CLUBS' agreement with\n19 YachtLife is that G|CLUBS would market YachtLife to its\n20 members, right?\n21 A. Could you repeat that.\n22 Q. Sure. Part of G|CLUBS' agreement with YachtLife was that\n23 G|CLUBS would market YachtLife to its members, right?\n24 A. G|CLUBS would promote the benefit to its members.\n25 Q. Okay. I'm just going to show you what's been marked as\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Defense Exhibit 20121.\n2 MR. KAMARAJU: And this is just for the witness and\n3 the parties.\n4 And maybe we can scroll through.\n5 Okay. Maybe we can go to the signature page that we\n6 were just on.\n7 Q. Okay. Do you see a signature line for G|CLUBS Operations?\n8 A. Yes.\n9 Q. Do you recognize that signature?\n10 A. Yes.\n11 Q. Do you recognize what this document is?\n12 MR. KAMARAJU: If you can go back to the first page if\n13 you need.\n14 A. The agreement.\n15 Q. Okay. And the signature that you recognize, whose\n16 signature is it?\n17 A. Max Troy.\n18 Q. And who is that?\n19 A. He worked at the partnership.\n20 Q. And I'm sorry. When you say partnership, he worked at a\n21 G|CLUBS partnership?\n22 A. A G|CLUBS——correct. Apologies.\n23 Q. Okay. And you said this is the agreement, this is the\n24 YachtLife agreement?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 MR. KAMARAJU: Okay. The defense would offer\n2 DX 20121, please.\n3 MR. FINKEL: No objection.\n4 THE COURT: It is admitted.\n5 (Defendant's Exhibit 20121 received in evidence)\n6 MR. KAMARAJU: Okay. Thank you.\n7 And could we publish that.\n8 Okay. So let's blow up paragraph 2 first, please.\n9 Oh, sorry. Before we do that, let's just blow up the\n10 top paragraph where it says, \"This strategic partner\n11 agreement.\"\n12 BY MR. KAMARAJU:\n13 Q. Okay. Now do you see it says, \"Entered into by and between\n14 G|CLUBS Operations LLC,\" and then it says \"the Company,\" right?\n15 A. Yes.\n16 Q. Okay. So this document uses the Company to refer to\n17 G|CLUBS Operations LLC, correct?\n18 A. Yes.\n19 Q. And then it says YachtLife Technologies Inc., and that's\n20 referred to as \"the Service Provider,\" right?\n21 A. Correct.\n22 MR. KAMARAJU: Okay. So now if we could blow up\n23 paragraph 2, please.\n24 Q. Okay. Now can you read 2a, please.\n25 A. \"Company shall advertise and market service provider's good\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 and services to its members.\"\n2 Q. Okay. So you understand that's G|CLUBS shall advertise and\n3 market YachtLife's goods and services to its members, right?\n4 A. Correct.\n5 Q. Okay. And then let's look at paragraph b. And you see it\n6 says, \"Service Provider shall provide to the Company and its\n7 eligible members——\"and then I'm going to skip the next\n8 part——\"certain services (collectively, 'the Services') stated\n9 as follows and as applicable due to the nature of Service\n10 Provider.\" Do you see that?\n11 A. Yes.\n12 Q. And then it goes on to the next page, right?\n13 THE COURT: All righty. We're at 2:30 and so we're\n14 going to take our break.\n15 Members of the jury, don't discuss the case amongst\n16 yourselves or with anyone else. Don't permit anyone to discuss\n17 the case in your presence. Don't read, listen to, or watch\n18 anything from any source that touches on the subject matter of\n19 this trial.\n20 Ms. Reyes, you may step out. Don't discuss your\n21 testimony.\n22 (Jury not present; witness not present)\n23 THE COURT: Please be seated.\n24 So during this break I have to attend to another\n25 matter and so to the extent that you want to raise something,\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 it will be when we return.\n2 MR. KAMARAJU: Thank you, your Honor.\n3 (Recess)\n4 (Jury present)\n5 THE COURT: You may continue your inquiry.\n6 MR. KAMARAJU: Thank you, your Honor.\n7 I think we had up on the screen DX 2121.\n8 BY MR. KAMARAJU:\n9 Q. Ms. Reyes, do you have it up on your screen?\n10 A. Yes.\n11 Q. Okay. Great.\n12 MR. KAMARAJU: Jurors have it?\n13 Q. Okay. So I think we talked about provision (a) already, so\n14 let me just go back to that quickly.\n15 So you see services are, \"The company shall advertise\n16 and market service provider's good and services to its\n17 members.\" You see that, right?\n18 THE COURT: Mr. Kamaraju, I think that the jury would\n19 benefit from just hearing again the parties to this——\n20 MR. KAMARAJU: Hundred percent, your Honor. Thank\n21 you.\n22 THE COURT: ——document.\n23 MR. KAMARAJU: Let me remind them. So let's blow back\n24 out.\n25 And let's go to the very first paragraph.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 BY MR. KAMARAJU:\n2 Q. Okay. So you see here it says, \"This strategic partner\n3 agreement,\" and then it goes on. I'm going to skip the date.\n4 It says, \"Entered into by and between G Club Operations LLC.\"\n5 Do you see that?\n6 A. Yes.\n7 Q. Okay. And that's referred to here as the Company, right?\n8 A. Yes.\n9 Q. Okay. And YachtLife Technologies Inc. is referred to as\n10 the service provider, right?\n11 A. Yes.\n12 Q. Okay. And together, if you go on to the next sentence, it\n13 says \"may be referred to as the parties.\" You see that?\n14 A. Yes.\n15 Q. Now let's go back to paragraph 2.\n16 All right. So you see this, right?\n17 A. Yes.\n18 Q. Provision (a)?\n19 A. Yes.\n20 Q. Okay. And you understand that what G|CLUBS is giving under\n21 this agreement is advertising and marketing YachtLife's goods\n22 and services to G Club members, right?\n23 A. Yes.\n24 Q. Okay. G|CLUBS is not paying any money to YachtLife under\n25 this agreement, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. Correct.\n2 Q. Okay. But YachtLife entered into the agreement anyway,\n3 right?\n4 A. There's an agreement, correct.\n5 Q. Right. And YachtLife signed it.\n6 A. Yes.\n7 Q. Okay. And that's YachtLife's decision to do, right?\n8 A. Yes.\n9 Q. And you're not aware of any connection between YachtLife\n10 and Mr. Guo, right?\n11 A. Not that I'm aware.\n12 MR. KAMARAJU: Okay. We can take that down.\n13 I'd like to put up just for the witness, the Court and\n14 the parties DX 20235.\n15 Okay. Maybe we can just blow up the top first.\n16 Okay. And maybe we can scroll through this for\n17 Ms. Reyes.\n18 Keep going towards the signature page, please.\n19 BY MR. KAMARAJU:\n20 Q. Okay. Do you see the signature line there?\n21 A. Yes.\n22 Q. Okay. Who signed it on behalf of G|CLUBS Operations?\n23 A. I did.\n24 Q. Okay. And what company is this with? Sorry. Withdrawn.\n25 That's a bad question.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Who's the counterparty to this agreement other than\n2 G|CLUBS? Who's the contract with?\n3 A. Luxury Cruise Connections.\n4 Q. Okay. And this was a contract for an additional set of\n5 benefits for G|CLUBS members; is that right?\n6 A. It was contract for a partner, correct.\n7 MR. KAMARAJU: Okay. So the defense offers DX 20235.\n8 MR. FINKEL: No objection.\n9 THE COURT: It is admitted.\n10 (Defendant's Exhibit 20235 received in evidence)\n11 MR. KAMARAJU: Okay. So let's publish for the jury,\n12 please.\n13 BY MR. KAMARAJU:\n14 Q. Okay. And do you see the first WHEREAS clause, under\n15 Recitals?\n16 MR. KAMARAJU: If you can blow that up.\n17 A. Yes.\n18 Q. Okay. Could you read that.\n19 A. \"G|CLUBS is a luxury membership service with access to\n20 events, concierge services, benefits and special pricing for\n21 its members.\"\n22 Q. And when you signed this agreement, you believed that\n23 statement to be true, right?\n24 A. Yes.\n25 Q. Okay. Now the next WHEREAS clause, now this says company,\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 so this is referring to the company as Luxury Cruise\n2 Connection, right?\n3 A. Yes.\n4 Q. Okay. What does Luxury Cruise Connection do?\n5 A. I don't recall specifically.\n6 Q. Okay. Do you recall whether it has anything to do with a\n7 cruise line?\n8 A. I do recall there was an——they were working on a cruise\n9 line. I just don't know specifically.\n10 Q. Okay. And so what was your understanding of what G|CLUBS\n11 members were going to get through this contract?\n12 A. I'm not exactly sure. Could we look into it.\n13 THE COURT: So I need for you to speak into the\n14 microphone.\n15 MR. KAMARAJU: Okay. Let's go zoom out to the larger\n16 agreement, please.\n17 All right. So let's just look at 1(a), under Scope of\n18 Agreement.\n19 BY MR. KAMARAJU:\n20 Q. Okay. And you see it says company, and that's Luxury\n21 Cruise Connections, right?\n22 A. Yes.\n23 Q. Okay. And it agrees to provide members——that's G|CLUBS\n24 members, right?\n25 A. Correct.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Okay. With services and preferred terms set forth in\n2 Attachment A. Right?\n3 A. Yes.\n4 MR. KAMARAJU: Okay. And let's take that down. Let's\n5 go to the next paragraph.\n6 Q. Okay. And again, it says company, and that's, again,\n7 Luxury Cruise, right?\n8 A. Yes.\n9 Q. All right. And could you read that.\n10 A. \"Company will provide G|CLUBS with a code or other means in\n11 which members can request company's preferred terms regarding\n12 the serviced listed in Attachment A.\"\n13 Q. Okay. And you remember yesterday on direct Mr. Finkel\n14 asked you a number of questions about how G|CLUBS members could\n15 access certain benefits, right?\n16 A. Yes.\n17 Q. And you talked about how they could access certain benefits\n18 by visiting the website, right? Or a website? Sorry.\n19 A. Yes.\n20 Q. Right? Like a hotel website, for example?\n21 A. Correct.\n22 Q. Right? And they would put in a code, right, to access\n23 their benefits?\n24 A. Depending on, but some of them had a code, yes.\n25 Q. Okay. Just like what's referred to in this paragraph,\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 right?\n2 A. Yes.\n3 MR. KAMARAJU: Okay. Let's look at the next\n4 paragraph.\n5 Q. Could you read that, please.\n6 A. \"All services offered by company under this agreement will\n7 be sold to the members directly by company.\"\n8 Q. Okay. So you understand that to mean that Luxury Cruise\n9 will market directly to the G|CLUBS members, right?\n10 A. The services will be offered to the members directly by\n11 Luxury Cruise.\n12 Q. Okay. So that it's not going to go through G|CLUBS, right?\n13 A. Correct.\n14 MR. KAMARAJU: Okay. Let's keep scrolling down to the\n15 next page, please.\n16 Okay. Just let's blow up 3(a).\n17 Q. Do you see that?\n18 A. Yes.\n19 Q. Okay. So what's your understanding of this provision?\n20 A. I'm going to read it.\n21 That G|CLUBS is responsible for marketing to its\n22 members, the services offered by cruise.\n23 Q. Luxury Cruise?\n24 A. Thank you. Luxury Cruise.\n25 MR. KAMARAJU: All right. We could take that down for\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 now.\n2 And I'd like to pull up what's been marked for\n3 identification as DX 20234.\n4 Okay. And if we can just scroll through that for\n5 Ms. Reyes.\n6 BY MR. KAMARAJU:\n7 Q. Okay. Do you see a signature there on that page we were\n8 just on?\n9 A. Yes.\n10 Q. Okay. And who signs for G|CLUBS?\n11 A. I do.\n12 Q. Okay. And let's go back to the top paragraph, please. And\n13 do you see at the top it says Condado Vanderbilt?\n14 A. Yes.\n15 Q. Is this a partnership with Condado Vanderbilt Hotel?\n16 A. Yes.\n17 MR. KAMARAJU: The defense offers DX 20234.\n18 MR. FINKEL: No objection.\n19 THE COURT: It is admitted.\n20 (Defendant's Exhibit 20234 received in evidence)\n21 MR. KAMARAJU: Okay. So could we publish to the jury.\n22 Okay. Put it up on the screen.\n23 Q. Now the Condado Vanderbilt is located in San Juan, right?\n24 A. Correct.\n25 Q. It's a luxury hotel in that city?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. Yes.\n2 Q. And is it fair to say——or withdrawn.\n3 Is it your understanding that San Juan has a pretty\n4 vibrant tourist industry?\n5 A. Yes.\n6 Q. People come to visit Puerto Rico, right?\n7 A. Yes, they do.\n8 Q. Particularly in the winter?\n9 A. Any time of the year.\n10 Q. Okay. And G|CLUBS, when you joined G|CLUBS in December of\n11 2020, the COVID pandemic was still going on, correct?\n12 A. Yes.\n13 Q. And that made it difficult to secure travel benefits for\n14 G|CLUBS, right?\n15 A. Yes.\n16 Q. Okay. Because people weren't traveling as much anymore,\n17 right?\n18 A. During that time, no.\n19 Q. Right. Now under this agreement, if we can just bold——do\n20 you see where it says \"G|CLUBS will be honored\"? Do you see\n21 that?\n22 A. Yes.\n23 Q. Okay. Could you just read that first sentence.\n24 A. \"G|CLUBS will be honored a 15 percent off our best\n25 available rate as promoted on our hotel website with all\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 corporate amenities included.\"\n2 Q. Okay. And could you go on to read the next sentence,\n3 please.\n4 A. This discounted rate will be honored for all room\n5 categories.\n6 Q. Okay. So you understand that to mean whatever kind of room\n7 at the Condado, they will receive a discount, right?\n8 A. Correct.\n9 Q. And that's available specifically to G|CLUBS members under\n10 this agreement, right?\n11 A. Correct.\n12 Q. Do you know how much a room runs at the Condado?\n13 A. It depends on the season.\n14 Q. Fair enough. How about peak season?\n15 A. I'm not exactly sure, but I've seen a little bit over 500.\n16 MR. KAMARAJU: Now we can take out the blowout for a\n17 second.\n18 Now can we look at the——scroll down to the signature.\n19 Q. Okay. Do you see the date you signed this?\n20 A. Yes.\n21 Q. January 16, 2023, correct?\n22 A. Yes.\n23 Q. That's months after G|CLUBS got the subpoena, correct?\n24 A. Yes.\n25 Q. And that's months after there was a seizure of G|CLUBS'\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 accounts, correct?\n2 A. Yes.\n3 Q. So despite those events, you continued trying to secure\n4 benefits for G|CLUBS members, right?\n5 A. Yes.\n6 Q. In fact, you tried to secure benefits for G|CLUBS members\n7 throughout your time at the company, correct?\n8 A. Yes.\n9 Q. It was your job, right?\n10 A. Part of my job, yes.\n11 Q. Okay. And you remember Mr. Finkel asked you a number of\n12 questions about the G|CLUBS website on direct? Do you remember\n13 that?\n14 A. Yes.\n15 Q. And he took you through the website and he said, did\n16 G|CLUBS offer this service, right? Do you remember that?\n17 A. Yes.\n18 Q. And you responded not at that time, right?\n19 A. Yes.\n20 Q. And in one instance you responded, we were working on it\n21 but we didn't have it yet, right?\n22 A. Yes.\n23 Q. Because G|CLUBS was an evolving company, right?\n24 A. Yes.\n25 Q. You were building, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. Correct.\n2 Q. And you had started during the pandemic, right, at least\n3 when you joined?\n4 A. Yes.\n5 Q. And you were open about that with people, right?\n6 A. What do you mean by open?\n7 Q. Well, you weren't telling vendors that we're a fully formed\n8 company with all of our benefits put together, right?\n9 A. No.\n10 Q. And you weren't telling prospective members that, right?\n11 A. I don't believe I was telling prospective members——\n12 THE COURT: Okay.\n13 A. ——anything.\n14 THE COURT: I need for you to get really close to that\n15 microphone because it's sounding like a whisper.\n16 THE WITNESS: Sorry.\n17 A. Can you repeat it, please.\n18 MR. KAMARAJU: All right. I'm going to trouble the\n19 court reporter, if she doesn't mind, to read it back, please.\n20 THE COURT: Go ahead.\n21 (Record read)\n22 Q. Anything, right? That was the answer?\n23 A. On that——on the COVID.\n24 Q. Oh, yes. Sorry. I wasn't asking about COVID specifically.\n25 I was saying: You weren't telling prospective members that all\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 of G|CLUBS benefits were available right up at the front,\n2 right? That was not part of G|CLUBS marketing, right?\n3 MR. FINKEL: Objection. Compound, form.\n4 THE COURT: I'm going to permit the question.\n5 A. There were ongoing benefits.\n6 Q. Right. Additional benefits would be added down the line,\n7 right?\n8 A. Over time, yes.\n9 Q. Okay. So there were some benefits to start, right?\n10 A. Correct.\n11 Q. And when you joined, that included the G Fashion discount,\n12 right?\n13 MR. FINKEL: Asked and answered.\n14 THE COURT: You may answer.\n15 A. Yes, that was already in place.\n16 Q. Okay. And then during your time as CEO you added\n17 additional benefits, right?\n18 A. Correct.\n19 Q. And then you were seeking even more benefits, right?\n20 A. Correct.\n21 Q. 'Cause that was your job.\n22 A. It was part of my job, yes.\n23 Q. Now among the benefits that you were looking for potential\n24 G Club members, you were looking for immigration services,\n25 right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. I do not recall looking for that.\n2 MR. KAMARAJU: Okay. Just for the witness——I'd like\n3 to see if I can help you——can we just pull up for her DX 34063.\n4 I'm sorry. Actually, can we do DX 34064. My\n5 apologies. This is just for the witness and the parties and\n6 the Court.\n7 BY MR. KAMARAJU:\n8 Q. All right. Can you take a look at that.\n9 Okay. And just let me know when you're ready.\n10 A. I read it.\n11 Q. Okay. So don't read anything off the document out loud.\n12 My question is solely: Does looking at this document refresh\n13 your recollection as to whether G|CLUBS was looking into a\n14 potential immigration services for its members?\n15 A. I do not recall this document.\n16 MR. KAMARAJU: Okay. We can take it down then.\n17 Q. Do you remember looking for a bespoke luxury travel service\n18 through something called Internova?\n19 A. No, I do not recall that name.\n20 Q. Okay. How about looking for concierge services through a\n21 company called Bold Luxury?\n22 A. I do recall concierge service. I don't really know the\n23 name, but I do recall that.\n24 MR. KAMARAJU: Okay. Can we just show the witness,\n25 the Court, and the parties DX 31571.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. If you can just take a look at that for yourself.\n2 A. Yeah.\n3 MR. KAMARAJU: And if we can scroll through it for\n4 Ms. Reyes.\n5 A. Would you mind scrolling to the bottom?\n6 Q. Of course. Let's keep going.\n7 A. Yes.\n8 Q. Okay. Does this refresh your recollection as to whether\n9 that company was called Bold Luxury?\n10 A. Bold Luxury was a company for travel and transportation\n11 services.\n12 Q. Okay. And that was a company that G|CLUBS was seeking a\n13 partnership with, right?\n14 A. Correct.\n15 Q. Okay. Now as part of your responsibilities as a CEO, did\n16 you prepare a business plan to send to banks?\n17 A. Not that I recall.\n18 Q. Okay. Did you revise a business plan that was going to be\n19 sent to banks?\n20 A. Not that I recall.\n21 Q. Do you recall ever revising a G|CLUBS business plan for any\n22 purpose?\n23 A. Yes, I believe so.\n24 Q. Okay. So you remember doing so?\n25 A. Best of my recollection, there was a business plan created,\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 yes.\n2 MR. KAMARAJU: Okay. Could we pull up for the witness\n3 and the parties and the Court DX 60604, please.\n4 Q. Do you recognize this?\n5 A. Could you scroll.\n6 Q. Of course. Please. Take your time.\n7 Do you recognize this document, Ms. Reyes?\n8 A. Yes, I recall it.\n9 Q. What is it?\n10 A. The business plan.\n11 Q. Okay. And you were involved in revising this business\n12 plan?\n13 A. Me and other people, yes.\n14 Q. Sure. Not just you; you were one of the people who\n15 commented on it, right?\n16 A. To review it, yes.\n17 Q. Okay. And this is a draft?\n18 A. Looks like a draft, yes.\n19 MR. KAMARAJU: Okay. The defense would offer\n20 DX 60604.\n21 MR. FINKEL: May I inquire.\n22 THE COURT: You may.\n23 VOIR DIRE EXAMINATION\n24 BY MR. FINKEL:\n25 Q. Ms. Reyes, do you know if this draft was sent out, this\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 version?\n2 A. I'm not sure.\n3 MR. FINKEL: Objection. Hearsay. And relevance.\n4 THE COURT: Are you offering it to show that there was\n5 a draft?\n6 MR. KAMARAJU: Yeah, just that they were discussing it\n7 internally; that's all.\n8 THE COURT: Do you recognize the document?\n9 THE WITNESS: I recognize the document, the format of\n10 it.\n11 MR. FINKEL: We object to it for that purpose as well,\n12 internal discussion.\n13 THE COURT: Overruled. You may ask your question.\n14 MR. KAMARAJU: Thank you, your Honor. Can I publish\n15 it to the jury?\n16 THE COURT: Yes.\n17 (Defendant's Exhibit 60604 received in evidence)\n18 MR. KAMARAJU: Okay. Thank you. Can we publish it to\n19 the jury, please.\n20 BY MR. KAMARAJU:\n21 Q. Okay. Now, Ms. Reyes, you testified that a number of\n22 different people commented on this, correct?\n23 A. It wasn't just me that reviewed this document.\n24 Q. Sure. Do you remember who else within the company reviewed\n25 it?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 A. Legal.\n2 Q. Okay. I'm not going to ask you about any of the\n3 discussions with legal. Do you remember if there was anybody\n4 other than legal who reviewed it?\n5 A. I don't recall at the time.\n6 MR. KAMARAJU: Okay. Can we scroll down, please.\n7 Keep going.\n8 Keep going.\n9 Q. All right. Do you see under Proposed Future Benefits,\n10 subsection B?\n11 A. Yes.\n12 Q. Can you look at 1.\n13 A. Yes.\n14 Q. Okay. What's 1?\n15 A. Multi membership.\n16 Q. Okay. And can you just read that.\n17 A. \"We foresee a member would purchase multiple memberships\n18 for access to multiple benefits and inheritance reasons.\n19 Exclusive benefits for our multi members may include the\n20 ability to have multiple participations in events like the\n21 summits and talks, as well as promotions offered in those\n22 events.\"\n23 Q. And what was the purpose of developing a business plan at\n24 this time?\n25 A. I'm not sure at the time, but I do recall the business plan\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 was part of the requirements for the tax incentive decree.\n2 Q. Okay. Can you just explain to the jury what tax incentive\n3 decree you're talking about.\n4 A. It's the Act 60 tax incentive.\n5 Q. Okay. Without getting into too many particulars, that's a\n6 Puerto Rican law of some sort?\n7 A. It's a Puerto Rican tax incentive.\n8 Q. And it creates certain kinds of tax incentives for certain\n9 kinds of businesses in Puerto Rico?\n10 A. I'm not exactly sure how it specifically incorporates the\n11 tax incentive.\n12 Q. But G|CLUBS was benefiting from that incentive, right?\n13 A. Correct.\n14 Q. Okay. And can you explain to us how this document\n15 connected to the G|CLUBS receiving the tax incentive.\n16 Withdrawn.\n17 Let me pull it back from this document.\n18 Why was G|CLUBS creating a business plan in connection\n19 with the tax incentive?\n20 A. To the best of my recollection, it was a requirement.\n21 Q. Okay.\n22 THE COURT: Are you saying that it was a requirement\n23 in order to qualify for the benefit?\n24 THE WITNESS: In order to submit——correct, to apply\n25 for the Act 60 benefit.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Okay. And to your knowledge did G|CLUBS submit for that\n2 benefit?\n3 A. Yes.\n4 Q. Okay. Now did you submit an application to a Puerto Rican\n5 governmental entity to get that benefit? Not you, G|CLUBS, I\n6 mean.\n7 A. It's a Puerto Rican entity, correct.\n8 Q. Okay. Do you know who gets the application?\n9 A. Can I say it in Spanish, the name of the agency?\n10 Q. It's up to your Honor. I don't know if that——\n11 THE COURT: You can say it. Go ahead.\n12 A. Departamento de Desarollo Economico y Comercio. So\n13 Department of Economic——\n14 Q. Just whatever you remember is fine. It's a Puerto Rican\n15 governmental department of some sort?\n16 A. Yes.\n17 Q. Okay. Can we now go to, in the same Proposed Future\n18 Benefits section, No. 5.\n19 Okay. Do you see this?\n20 A. Yes.\n21 Q. All right. So this is, again, a discussion about physical\n22 clubs, correct?\n23 A. Yes.\n24 Q. And this is what was being discussed within G|CLUBS, right?\n25 A. Correct.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Okay. Do you see where it says, \"Our members will be able\n2 to enjoy the benefits and amenities of the club including,\" and\n3 then it lists a number of things, and then it says, \"allowing\n4 them to securely congregate in luxury with other like-minded\n5 individuals.\" Do you see that?\n6 A. Yes.\n7 Q. What's your understanding of the phrase \"allowing them to\n8 securely congregate in luxury with other like-minded\n9 individuals\"?\n10 A. For them to meet in luxury, like in high end, with other\n11 like-minded people.\n12 Q. And what about the phrase \"securely\"?\n13 A. Not exactly sure. Secure.\n14 Q. Sorry. I didn't hear you.\n15 A. I'm not exactly sure what does it mean specifically. It's\n16 a——like a safe place?\n17 Q. Okay. Now you understood this was going to a government\n18 department of some sort, right?\n19 A. Yes.\n20 Q. And it was to enjoy some kind of benefit, right?\n21 A. Correct.\n22 Q. It was important for this to be accurate, right?\n23 A. Yes.\n24 Q. Okay. Now you testified——\n25 MR. KAMARAJU: We can take that down.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 You testified about a trip that you took to London,\n2 England. Do you remember that?\n3 A. Yes.\n4 Q. Were there two trips to London or just one?\n5 A. Just one.\n6 Q. Okay. And while you were in London, you toured a castle in\n7 the English countryside, right?\n8 A. There were two hotels.\n9 Q. Okay. Two hotels. All right. And you were touring them\n10 in your capacity as G|CLUBS CEO, right?\n11 A. Correct.\n12 Q. All right. It wasn't a personal trip to go see them,\n13 right?\n14 A. No.\n15 MR. KAMARAJU: Okay. Could we show the witness and\n16 the parties DX 60595.\n17 Q. Is this a photograph of one of the hotels that you toured?\n18 A. Yes.\n19 Q. Is it a fair and accurate depiction of one of the hotels?\n20 A. I'm sorry?\n21 Q. Is it a fair and accurate depiction of that hotel? Does it\n22 look like the hotel that you toured?\n23 A. Yes.\n24 MR. KAMARAJU: Okay. The defense offers DX 60595.\n25 MR. FINKEL: No objection.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 THE COURT: It is admitted.\n2 (Defendant's Exhibit 60595 received in evidence)\n3 MR. KAMARAJU: Could we publish it, please.\n4 Q. All right. So do you remember what the name of this place\n5 was?\n6 A. I'm not exactly sure. Glutenten [ph] or something like\n7 that if I'm not mistaken.\n8 Q. All right. But it's a luxury hotel, right?\n9 A. Yes.\n10 Q. And the idea was that it could be rented out for G|CLUBS\n11 members, right?\n12 A. It could be offered as a benefit, for members.\n13 Q. And specifically for G|CLUBS members, right?\n14 A. Correct.\n15 Q. And there were a number of G|CLUBS members who lived in\n16 Europe, right?\n17 A. Yes.\n18 Q. Okay. So this might be convenient for them, right?\n19 A. Would be a benefit for them.\n20 Q. Sure. Now you said there were two properties you looked\n21 at, right?\n22 A. Yes.\n23 Q. Okay. Well, before we go to that one, did you actually\n24 tour this hotel?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 Q. Was it pretty luxurious?\n2 A. Pretty nice, yes.\n3 Q. Pretty big?\n4 A. Yes.\n5 Q. Do you remember how much a room cost at that hotel?\n6 A. No. I don't remember specifically.\n7 Q. Okay. Do you remember if it was more than what the Condado\n8 charged at the peak?\n9 A. I believe so.\n10 Q. Okay. A lot more?\n11 A. I'm not exactly sure.\n12 Q. Okay. Now we were going to the second property. You said\n13 there was a second one that you also toured, right?\n14 A. Yes.\n15 MR. KAMARAJU: Okay. Could we show Ms. Reyes what's\n16 been marked as DX 60597.\n17 Q. All right. Is this a photograph of the other hotel that\n18 you visited? Oh, I'm sorry.\n19 A. It looks like it, yes.\n20 Q. Okay. And this photograph depicts that hotel; is that\n21 right?\n22 A. Yes.\n23 MR. KAMARAJU: Okay. The defense offers DX 60597.\n24 MR. FINKEL: No objection.\n25 THE COURT: It is admitted.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6I1GUO4 Reyes - Cross\n1 (Defendant's Exhibit 60597 received in evidence)\n2 MR. KAMARAJU: Okay. Could we publish it, please.\n3 Q. Okay. So again, you actually toured this hotel?\n4 A. Yes.\n5 Q. All right. And pretty luxurious; fair to say?\n6 A. Yes.\n7 Q. Pretty expensive, right?\n8 A. Yes.\n9 Q. Lots of services for guests of the hotel?\n10 A. They had different services, yes.\n11 (Continued on next page)\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 BY MR. KAMARAJU:\n2 Q. Was there a spa?\n3 A. Yes.\n4 Q. Were there conference rooms?\n5 A. I don't remember.\n6 Q. Places for guest to meet?\n7 A. Yes.\n8 Q. Bar maybe?\n9 A. Yes.\n10 Q. All right. Now, Mr. Guo never asked you to tour any other\n11 places, right?\n12 A. No.\n13 Q. He never spoke to you about them at all, right?\n14 A. Not that I recall.\n15 Q. You never told him you was going to look at them?\n16 A. No.\n17 Q. You never told him about the island you were looking for,\n18 right?\n19 A. Not that I recall.\n20 Q. You didn't communicate any of that with the spokesperson\n21 for G/Clubs, right?\n22 A. Could you repeat.\n23 Q. Sure. It's okay. You didn't communicate anything about\n24 these particular properties to Mr. Guo, correct?\n25 A. Not that I recall.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. You never had a discussion with him about it, right?\n2 MR. FINKEL: Asked and answered.\n3 THE COURT: Sustained.\n4 Q. Now, did you fly commercial to London? No. Withdrawn.\n5 You testified on direct that you took a private jet,\n6 correct?\n7 A. Yes.\n8 Q. Was that a G/Clubs jet?\n9 A. Not that I'm aware of.\n10 Q. Do you know if G/Club chartered the jet?\n11 A. I don't believe so.\n12 Q. Do you know who owned the jet?\n13 A. I'm not sure.\n14 Q. We could take that down.\n15 G/Clubs Operation, that was based in Puerto Rico,\n16 right?\n17 A. Yes.\n18 Q. And it had a parent company that I think you referred to it\n19 as International, right, or BVI?\n20 A. Yes.\n21 Q. BVI owned 100 percent of operations, right?\n22 A. Can you repeat that.\n23 Q. Sure. BVI owned a hundred percent of operations, right?\n24 A. I'm not exactly sure. BVI was on top of G/Club operations.\n25 Q. Let me ask the question this way.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 You refer to Mr. He as the owner, right?\n2 A. Correct.\n3 Q. He was the owner of G/Club BVI?\n4 A. To my understanding, yes.\n5 Q. And through that he was the owner of operations, right?\n6 A. Correct.\n7 Q. And you had that email exchange with him where you said,\n8 I'm not trying to be the owner -- I'm paraphrasing -- right,\n9 cause he was the owner, right?\n10 A. Yes.\n11 Q. And you knew that G/Clubs was trying to expand\n12 internationally, correct?\n13 A. What do you mean expand internationally?\n14 Q. There was an effort to build the company out in the Middle\n15 East, right?\n16 A. I was not involved in that.\n17 Q. But you were aware of it, right?\n18 A. I was told at some point.\n19 Q. You knew that Alex Hadjicharalambous, you knew that he was\n20 the controller of G/Clubs operations, right?\n21 A. Yes.\n22 Q. And he went to the Middle East as part of that effort,\n23 right?\n24 MR. FINKEL: Objection. She testified she knows about\n25 this based on what she was told.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 THE COURT: Do you know whether he went to the Middle\n2 East?\n3 THE WITNESS: Yes, he went to the Middle East.\n4 Q. Just to stay on Alex for a second, his responsibilities as\n5 controller were to manage bank accounts; is that correct?\n6 A. Yes.\n7 Q. Manage the company's cash flow, right, keep track of it?\n8 A. Of the accounts?\n9 Q. Yeah, sure.\n10 A. Yes.\n11 Q. Keep track of the money going out and coming in, right?\n12 A. He had access.\n13 Q. That wasn't your job, right?\n14 A. No.\n15 Q. You had other responsibilities?\n16 A. Yes.\n17 Q. When Mr. Finkel asked you all those questions about the\n18 loans being repaid, you weren't looking at the bank accounts to\n19 see if that happened, right?\n20 THE COURT: I can't hear you.\n21 A. No, I didn't.\n22 THE COURT: Speak up.\n23 A. Could you repeat that.\n24 Q. So when Mr. Finkel asked you those questions about whether\n25 the loans had been repaid, do you know what loans I'm referring\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 to?\n2 A. Yes.\n3 Q. When he asked you the questions about that, it wasn't your\n4 job to go look at the bank statements to see if the loans had\n5 been repaid, correct?\n6 A. I did not look at the bank statements.\n7 Q. And that wasn't your responsibility?\n8 A. I didn't view that as my responsibility.\n9 Q. There were other people at the company responsible for\n10 that, right?\n11 A. Yes.\n12 Q. Because in a company you can have a division of labor,\n13 right?\n14 A. Yes.\n15 Q. The CEO is not necessarily responsible for everything,\n16 right?\n17 A. I don't believe so.\n18 Q. You had several departments that reported to you, right?\n19 A. Yes.\n20 Q. And you relied on their advice, right?\n21 A. Yes.\n22 Q. Now, you testified about meeting Mr. He and Mileson Guo on\n23 a yacht outside of Europe, correct?\n24 A. Yes.\n25 Q. Do you remember approximately what year that was?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. 2021.\n2 Q. Do you remember if it was in the summer, when it was\n3 generally?\n4 A. September.\n5 Q. And so do you think you'd recognize Mileson today?\n6 A. I'm not exactly sure.\n7 Q. Could we pull up, it's already in evidence, GXHN-82, please\n8 and publish it.\n9 Do you see it?\n10 A. Yes.\n11 Q. Do you recognize that guy?\n12 A. I'm not exactly sure, no.\n13 Q. We can take it down. On direct you did recognize Mr. He,\n14 right?\n15 A. Yes.\n16 Q. And Mr. He owned 100 percent of BVI, right?\n17 MR. FINKEL: Asked and answered.\n18 THE COURT: Sustained.\n19 Q. So Mr. He controlled all of the assets in the company,\n20 right?\n21 A. What do you mean by control the assets?\n22 Q. I mean he made the decision about where certain money would\n23 go, right?\n24 A. Yes.\n25 Q. So he asked you to make certain loans, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. Yes.\n2 Q. And you made them, right?\n3 A. Made loans, yes.\n4 Q. And sometimes he asked you for loans to make investments,\n5 right?\n6 A. There were different purposes for the loans.\n7 Q. So, for example, one time he asked for a loan to make an\n8 investment in something called Yield Esta, right?\n9 A. I recall Yield Esta.\n10 Q. And Mr. He asked you to put money into that company, right?\n11 A. It's not a -- to my understanding it's not a company.\n12 Q. What's your understanding of what it is?\n13 A. It's a product from a bank, like a bank account.\n14 Q. It's an investment product of some sort?\n15 A. I'm not exactly sure. It's among, like, the account in the\n16 bank. You had to have the Yield Esta, the funds.\n17 Q. G/Clubs transferred $3 million to Yield Esta at the start\n18 of the relationship with Mercantile Bank; isn't that right?\n19 A. Correct.\n20 Q. And what did you understand the $3 million was going to be\n21 doing?\n22 A. It was funds in that account in order to have our account.\n23 Q. So the money was just going to sit there?\n24 A. I understood that it was going to be there for a period of\n25 time.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. And then what would happen next?\n2 A. I'm not sure.\n3 Q. Were you involved in transferring the $3 million to Yield\n4 Esta?\n5 A. I do the transfer?\n6 Q. In any way were you involved in that transfer, not that you\n7 just press the button, but in any way were you involved?\n8 A. I don't recall specifically. I recall the Yield Esta.\n9 Q. How did you find out about it then?\n10 A. About who, about Yield Esta?\n11 Q. The $3 million that G/Clubs put in Yield Esta, how did you\n12 find out about it?\n13 A. That was a product that was provided by Mercantile bank.\n14 MR. KAMARAJU: Motion to strike.\n15 THE COURT: He was asking you how did you come to know\n16 about Yield Esta.\n17 A. By Mercantile Bank.\n18 Q. Mercantile told you?\n19 A. That was their product.\n20 Q. And how did you find out that $3 million was invested by\n21 G/Clubs into Yield Esta?\n22 A. I believe that was a requirement. To open an account with\n23 them, you had to do. You have to have that amount in Yield\n24 Esta account.\n25 Q. So Mercantile -- your understanding is that Mercantile told\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 you that you had to invest this money?\n2 A. Correct.\n3 Q. And how did you find out that G/Clubs in fact invested that\n4 amount of money?\n5 A. How did I find out?\n6 Q. Yes, ma'am.\n7 A. I'm not exactly sure.\n8 Q. Are you done?\n9 A. I don't remember.\n10 Q. Now, Mr. He also decided to invest in something called\n11 Hamilton, right?\n12 A. There was a loan, correct.\n13 Q. And Mr. He is the one who directed that the loan should\n14 happen, right?\n15 A. I'm not exactly sure. It would come from Yvette or Mr. He.\n16 Q. You understand even if it came from Yvette, it was coming\n17 from Mr. He?\n18 A. Yes.\n19 Q. And Mr. He signed off on using those loan proceeds to go to\n20 Hamilton, right?\n21 A. He would sign off on the documents, the loan documents,\n22 yes.\n23 Q. And you were aware that those loan proceeds were going to\n24 Hamilton, right?\n25 A. I'm not exactly sure.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. Let's pull up what I believe is in evidence as GXGC-175.\n2 You see that?\n3 A. Yes.\n4 Q. This is an email from you to Mr. He, right?\n5 A. Yes.\n6 Q. And it's concerning a $50 million investment. Do you see\n7 that?\n8 A. Yes.\n9 Q. So what did you mean when you wrote, I'm writing with\n10 regards to the $50 million investment from G/Club International\n11 BVI into Hamilton Digital Assets?\n12 A. That's how the loan documents end. Resolutions would be\n13 reference as.\n14 Q. To write this sentence you had to know that there was going\n15 to be a $50 million investment by BVI into Hamilton Digital\n16 Assets, right?\n17 MR. FINKEL: Objection, mischaracterizes.\n18 THE COURT: Sustained.\n19 Q. So again, what did you mean?\n20 MR. FINKEL: Asked and answered.\n21 Q. What did you mean specifically about into Hamilton Digital\n22 Assets?\n23 MR. FINKEL: Asked and answered.\n24 THE COURT: Sustained.\n25 Q. Why did you send this email?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. Every time there was a loan across, I would send Mr. He the\n2 different loan documents and resolution for him to sign off on.\n3 Q. And which loan request did this pertain to?\n4 A. A $50 million loan to Hamilton Digital Assets.\n5 Q. Do you remember testifying about this exhibit with\n6 Mr. Finkel on direct?\n7 A. No, I do not.\n8 Q. So earlier today you have no recollection about talking\n9 about this exhibit?\n10 A. I don't recall specifically.\n11 Q. What was your understanding of what was going to happen\n12 with this $50 million once it got to Hamilton?\n13 A. I do not know.\n14 Q. Did you ask anybody to find out?\n15 A. I do not recall.\n16 Q. You don't recall if you asked anybody?\n17 A. I do not recall if I asked anyone.\n18 Q. Did you consider it part of your responsibilities as CEO of\n19 the company to know what was going to happen to this money?\n20 A. No.\n21 Q. That wasn't your job, right?\n22 A. I didn't view that as me asking.\n23 Q. That was Mr. He's decision, right?\n24 A. It was an instruction from Mr. He.\n25 Q. And it was his decision to make, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. Yes.\n2 Q. That's why you didn't ask him any questions about it,\n3 right?\n4 A. I didn't view as asking questions, no.\n5 Q. I'm sorry.\n6 A. I didn't view as asking questions, no. It was his\n7 instruction.\n8 Q. And that was his instruction to give, right?\n9 MR. FINKEL: Asked and answered.\n10 THE COURT: Sustained.\n11 Q. Now, do you remember being asked on direct some questions\n12 about Mr. He using a proton email account, right?\n13 A. Yes.\n14 Q. And you see here he's using a proton email account, right?\n15 A. Yes.\n16 Q. But you knew that was Mr. He, right?\n17 A. That was Mr. He's email?\n18 Q. That's the email you used to communicate with him, right?\n19 A. Yes.\n20 Q. He wasn't hiding it from you, right?\n21 A. No, I can see it.\n22 Q. Now, on direct Mr. Finkel asked you whether you knew why he\n23 used a proton email account and you had a G/Club account,\n24 remember that?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. You're an employee or at the time -- withdrawn.\n2 At the time you were an employee of G/Clubs\n3 operations, correct?\n4 A. Yes.\n5 Q. And you got your email account from G/Clubs operations,\n6 correct?\n7 A. Yes.\n8 Q. Mr. He was not an employee of G/Clubs operations, correct?\n9 A. No.\n10 Q. He was the owner, right?\n11 A. Yes.\n12 Q. You also talked about on direct how Mr. He talked to you\n13 about Puerto Ricans being slow. Do you remember that?\n14 A. Yes.\n15 Q. And he would complain about the pace of your work, right?\n16 A. Yes.\n17 Q. Now, you said that you spoke to Mr. Guo frequently. Do you\n18 remember that?\n19 MR. FINKEL: Mischaracterizes.\n20 THE COURT: Sustained.\n21 Q. How often did you speak to Mr. Guo?\n22 A. When I went to New York if he was in the office.\n23 Q. Never spoke to him in Puerto Rico?\n24 A. No.\n25 Q. Now, Mr. Guo was always nice to you, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. Yes.\n2 Q. He was polite, right?\n3 A. Yes.\n4 Q. He didn't make any comments about Puerto Ricans being slow,\n5 right?\n6 A. No.\n7 Q. He didn't do any of that, right?\n8 A. No.\n9 Q. And even at the dinner that you had with him, the one that\n10 Mr. Finkel asked you about, right, you remember that dinner?\n11 A. Yes.\n12 Q. And that occurred after G/Club had gotten the subpoena,\n13 right?\n14 A. Yes.\n15 Q. And Mr. Finkel asked you questions about Mr. Guo's comments\n16 about loyalty, right?\n17 A. Yes.\n18 Q. He didn't tell you that you had to be loyal, right?\n19 A. Not that I recall, no.\n20 Q. He talked about the loyalty that his brother showed to an\n21 ideal, right?\n22 A. Yes.\n23 Q. And that loyalty got his brother killed according to\n24 Mr. Guo at that dinner, right?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. That's what he talked to you about loyalty, right?\n2 A. Yes.\n3 Q. Now, you talked about on direct how you didn't discuss the\n4 structure of the loans that you testified about with Ms. Wang.\n5 Do you remember that?\n6 MR. FINKEL: Mischaracterizes.\n7 THE COURT: Sustained.\n8 Q. Did you discuss the structure of the loans from operations\n9 to BVI with anybody at G/Clubs?\n10 A. To the best of my recollection with legal.\n11 Q. I'm not asking about legal. But based on your\n12 conversations, what was your understanding as to why it was\n13 being done that way?\n14 A. I don't recall. That's how it was structured.\n15 Q. Now, you also testified on direct that there was a loan\n16 request that an in-house attorney told you not to do, right?\n17 MR. FINKEL: Mischaracterizes.\n18 THE COURT: Sustained. Are you talking about the $5\n19 million?\n20 MR. KAMARAJU: She testified that a lawyer told her\n21 not to do it.\n22 THE COURT: She didn't characterize it as a loan.\n23 Q. My apologies. I'll withdraw it. The $5 million\n24 transaction, fair enough, you know the one what I'm talking\n25 about?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. Yes.\n2 Q. An in-house lawyer at G/Clubs told you not to do it?\n3 A. Not to execute on that.\n4 Q. When did that happen?\n5 A. The end of 2022. I don't know exactly the month. I don't\n6 recall exactly the month.\n7 Q. So after you got the subpoena?\n8 A. To the best of my recollection, yes, correct.\n9 Q. You didn't quit, right?\n10 A. When?\n11 Q. At that time when the $5 million got executed, you didn't\n12 quit, right?\n13 A. No, I didn't.\n14 Q. And you didn't think you were committing any crime at that\n15 time either, right?\n16 A. No, I did not.\n17 Q. And that's true even though you were going against that\n18 lawyer's advice, right?\n19 A. Correct.\n20 Q. I want to talk a little bit about refunds. Remember you\n21 were asked about that on direct?\n22 A. Yes.\n23 Q. Now, G/Club did allow people to cancel their membership,\n24 right?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. And it's not really a cancellation, but G/Club members\n2 could let their memberships lapse, right?\n3 A. What do you mean by lapse?\n4 Q. If there was an annual fee, they had to pay, right?\n5 A. Yes.\n6 Q. And that was in addition to whatever the initial fee they\n7 paid, right?\n8 A. Correct.\n9 Q. Just by way of the example, they may have paid $50,000 for\n10 the initial fee, and they would have some rolling annual fee\n11 going forward, right?\n12 A. They had their initial fee and annual fee, correct.\n13 Q. And if they stopped paying their annual fee, then I think\n14 you said that they're account was deactivated, right?\n15 A. Yes, there was a term to it.\n16 Q. I'm sorry.\n17 A. There's a specific term it's deactivated.\n18 Q. And they couldn't use the services anymore?\n19 A. They couldn't use the benefits, correct.\n20 Q. But G/Club did allow for you to, just for a member, to just\n21 cancel straight out their membership, right?\n22 A. There was a cancellation period.\n23 Q. There was a period of time in which that could happen,\n24 right?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. Now, Mr. Guo did not set that period of time, right?\n2 A. Not that I recall.\n3 Q. And when it changed from three days to I think you said it\n4 was either 12 or 14 days, right?\n5 A. Yes.\n6 Q. You didn't consult Mr. Guo about that change either, right?\n7 A. Not that I recall, no.\n8 Q. That was a G/Clubs corporate policy, right?\n9 A. It was a G/Club policy, yes.\n10 Q. And the policy was that if somebody asked for a refund\n11 outside of the -- let's just use 14-day window, they were\n12 entitled to a refund, yes?\n13 A. If it was outside of the 14 days, they were not entitled to\n14 a refund.\n15 Q. Was there a process at G/Clubs about processing refunds?\n16 A. Yes.\n17 Q. Could you describe it for the jury?\n18 A. The ones that were outside or the ones -- what type of --\n19 three day or the 14-day?\n20 Q. Let's say one came in within two days, what happens then?\n21 A. Member would send an email to us. That email would be sent\n22 to legal. Legal would review what we call the ticket, and they\n23 would approve or deny the request for the cancellation.\n24 Q. Were you involved in that process at all?\n25 A. Not on the process of approving or denying cancellation.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. To your knowledge was Mr. Guo involved in that process?\n2 A. No.\n3 Q. What happens if a member submitted, let's use the three-day\n4 period for right now. Okay.\n5 A. Yes.\n6 Q. Let's say a member submitted it six days outside of the\n7 refund period, is there a different process?\n8 A. It's the same process. The evaluation is different.\n9 Q. How is the evaluation different?\n10 A. Because it's outside the period, so that won't get\n11 canceled.\n12 Q. So if somebody submits outside the period, they don't get a\n13 refund, right?\n14 A. At some point they did not, yes.\n15 Q. Now, you testified on direct about knowing what the farms\n16 were. Do you remember that?\n17 A. Could you repeat that.\n18 Q. You know what the farms are, right?\n19 A. I'm not exactly sure how they work.\n20 Q. You have a general understanding as to what they are is all\n21 I'm asking?\n22 MR. FINKEL: Asked and answered, mischaracterizes.\n23 THE COURT: Sustained.\n24 Q. Do you have a general understanding?\n25 MR. FINKEL: Asked and answered.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 THE COURT: Sustained.\n2 Q. Were the farms involved in the refund process at G/Clubs?\n3 A. Not that I recall.\n4 Q. During your time at G/Clubs, do you remember how many\n5 refund request there were?\n6 A. No.\n7 Q. Ballpark?\n8 A. I'm not sure.\n9 Q. More than a hundred?\n10 A. I believe so.\n11 Q. More than a thousand?\n12 A. I'm not sure, could have. I'm not sure.\n13 Q. You testified also about sweepstakes, right?\n14 A. Yes.\n15 Q. Now, some of the people who won the sweepstakes, they live\n16 in China?\n17 A. Yes.\n18 Q. And could G/Clubs ship a prize to China?\n19 A. The ability to do it or if it was received?\n20 Q. Well, was it your understanding that G/Clubs could ship\n21 like a Lamborghini to China?\n22 A. No, we cannot ship a car.\n23 Q. And you're not aware if Mr. Guo ever telling you not to\n24 give a sweepstakes winner a prize, right?\n25 A. Not that I recall.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. Let's stick with cars for a second.\n2 Now, you met Mr. Guo, Mileson Guo on a yacht, and he\n3 discussed how he liked race car driving, right?\n4 A. Yes.\n5 Q. It was your impression that he was pretty well-connected in\n6 that world, right?\n7 A. To my understanding, yes.\n8 Q. In fact, he connected G/Clubs with the Bugatti dealership,\n9 right?\n10 A. That's what I was told.\n11 Q. Could we publish Government Exhibit 227, please. And we\n12 can publish this for the jury please.\n13 Do you see it?\n14 A. Yes.\n15 Q. This is an email you received from Lonny Soza, right?\n16 A. Yes.\n17 Q. And you can see that he's the president of Post Oak Motor\n18 Cars, right?\n19 A. Yes.\n20 Q. And this is relate to the Bugatti that G/Clubs purchased,\n21 right?\n22 A. The Bugatti, yes.\n23 Q. You see the date that this was sent November 1, 2021,\n24 right?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. Could you we go to page three, please.\n2 You see a customer name there?\n3 A. Yes.\n4 Q. Who's listed there?\n5 A. Mileson Guo.\n6 Q. Could we bring up alongside that GX-230 which is also in\n7 evidence. You see the document on the right?\n8 A. Yes.\n9 Q. That's another email from Mr. Soza to you, right?\n10 A. Yes.\n11 Q. And it's dated November 12, 2021, right?\n12 A. Yes.\n13 Q. And it's about that same Bugatti purchase?\n14 A. Yes.\n15 Q. Can we go to page four, please. You see this?\n16 A. Yes.\n17 Q. You see the customer name?\n18 A. Yes.\n19 Q. Who's listed as the customer's name there?\n20 A. G/Club International Limited.\n21 Q. Did you tell Mr. Soza to make that change?\n22 A. I don't remember.\n23 Q. Do you know if there was any other G/Club employees\n24 communicating with Mr. Soza about this purchase?\n25 A. Not that I was aware of.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. Do you know why this change was made?\n2 A. The loan was to G/Club international limited.\n3 Q. Not to Mileson Guo, correct?\n4 A. Correct.\n5 Q. Mileson Guo wasn't buying this car, right?\n6 A. Not to my understanding.\n7 Q. Even though his name is on this customer speck on the left\n8 side, right?\n9 A. Yes.\n10 Q. Now, you were asked whether Bugatti was ever made available\n11 to G/Club members, right?\n12 A. Not sure the Bugatti or -- I'm not sure if it was the\n13 Bugatti or the Lamborghini, not sure.\n14 Q. Do you know -- withdrawn.\n15 Do you know if the Bugatti ever left the lot?\n16 A. The dealership?\n17 Q. Yeah.\n18 A. To my understanding, no.\n19 Q. So you have no way of knowing if it ever could have been\n20 made available to G/Club members, right?\n21 MR. FINKEL: Calls for speculation.\n22 THE COURT: You can answer whether you know whether it\n23 was made available.\n24 A. To my understanding it was not made available.\n25 Q. Now, Mr. Finkel asked you about your role in picking the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Lamborghini. Do you remember that?\n2 A. Yes.\n3 Q. Prior to your time as CEO of G/Club, had you ever bought a\n4 Lamborghini before?\n5 A. No.\n6 Q. Did you ever negotiate a Lamborghini sale?\n7 A. No.\n8 Q. Ever toured a Lamborghini facility?\n9 A. No.\n10 Q. You ever visited a Lamborghini dealership?\n11 A. No.\n12 Q. Did you ever dream about buying a Lamborghini?\n13 A. Dreamed?\n14 Q. Yeah.\n15 A. No.\n16 Q. Fair to say you didn't have a lot of experience with\n17 purchasing Lamborghini-s?\n18 A. No.\n19 Q. He also asked you about camper vans that G/Club purchased.\n20 Do you remember that?\n21 A. Yes.\n22 Q. You ever seen a video of Mr. Guo camping?\n23 A. No.\n24 Q. You ever seen Mr. Guo advertise a camper in a video?\n25 A. No.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. You ever heard anyone say Mr. Guo went camping?\n2 MR. FINKEL: Objection.\n3 THE COURT: Overruled. You may answer.\n4 A. No, I've never heard.\n5 Q. So as the CEO of G/Club, you were aware that the Bugatti\n6 was being purchased, right?\n7 A. Yes.\n8 Q. And you were aware that the Lamborghini was being\n9 purchased, right?\n10 A. Yes.\n11 Q. And you knew that both cars were supposed to be delivered\n12 to Connecticut, right?\n13 A. I don't remember the delivery specifically.\n14 Q. You don't remember Mr. Finkel was asking about what CT\n15 means?\n16 A. I know what CT means. I didn't remember knowing that it\n17 was going to be delivered there.\n18 Q. Now, you testified that there were a lot of G/Club members\n19 in New York, right?\n20 A. There are G/Clubs in New York, yes.\n21 Q. Now, was it your understanding that before any of these\n22 cars could be used, there had to be special insurance obtained,\n23 right? There had to be insurance obtained, right?\n24 A. Yes.\n25 Q. And G/Club was having trouble obtaining that insurance,\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 right?\n2 A. They were working on it.\n3 Q. They were working on it, right?\n4 MR. FINKEL: Asked and answered.\n5 Q. Withdrawn. And you testified on direct I believe that you\n6 had approached a firm of some sort to handle that rental\n7 situation; is that fair?\n8 A. It was a firm to work with future benefits of renting for\n9 members, yes.\n10 Q. And that was in 2022, right?\n11 A. To the best of my recollection, yes.\n12 Q. G/Clubs pay the firm?\n13 A. I believe so.\n14 Q. So the firm was working on it, right?\n15 A. Yes.\n16 Q. Now, you testified that you saw the Lamborghini being\n17 driven by Mr. Guo in a video, right?\n18 A. Not driven.\n19 Q. Please tell me.\n20 A. It was a Lamborghini that was like showcased on a video.\n21 Q. Got it. So he showcased it in a video, right?\n22 A. Yes.\n23 Q. And you were concerned because the Lamborghini wasn't ready\n24 yet for consumption by G/Clubs members, right?\n25 A. G/Club had not put in place or offered that sort of\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 service.\n2 Q. It was still working on whatever it needed to offer that\n3 service, right?\n4 A. Correct.\n5 Q. And you in fact never heard that Mr. Guo was actually\n6 driving the Lamborghini, right?\n7 MR. FINKEL: Objection, hearsay.\n8 THE COURT: You can testify as to what you know.\n9 A. I'm sorry.\n10 THE COURT: Do you know if he was driving the\n11 Lamborghini?\n12 THE WITNESS: I didn't see him driving. It was just\n13 like parked.\n14 Q. And you never heard anything similar about a video\n15 involving him and the Bugatti, right?\n16 MR. FINKEL: Same objection. What she heard, hearsay.\n17 THE COURT: Talk about what you know as opposed to\n18 what you heard.\n19 A. I didn't know of him driving a Bugatti.\n20 Q. Now, before somebody could become a G/Club member, there\n21 was a vetting process, right?\n22 A. What do you mean a vetting process?\n23 Q. There was like a 30-day-period between when the application\n24 was submitted and when G/Clubs would accept it, right?\n25 A. I don't remember that.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. Was it instantaneous?\n2 A. The approval?\n3 Q. Mm hm.\n4 A. Members would fill out the application. And once it was\n5 received and payment was received, then they would get\n6 approved.\n7 Q. Was there ever any kind of requirement what was called KYC?\n8 A. Yes, there was a time.\n9 Q. When was that?\n10 A. That was, best of my recollection, either late 2022\n11 December or early 2023.\n12 Q. Do you remember Alex H having to work on sort of a\n13 reconciliation project paring membership agreements with money\n14 that was coming in?\n15 A. Member payments needed to be reconciled.\n16 Q. Just so we're saying the same thing, what do you mean when\n17 you say they needed to be reconciled?\n18 A. When a member receives a payment, when we receive a member\n19 payment that has to match the application on the system.\n20 Q. And Alex H was handling that on the G/Club side?\n21 A. Under financing.\n22 Q. And given the amount of money coming in, that was a bit\n23 overwhelming for the company, right?\n24 MR. FINKEL: Objection.\n25 THE COURT: Overruled. You can answer if you thought\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 it was overwhelming.\n2 A. There were a lot of member payments.\n3 Q. That's why you brought in Crane, right?\n4 A. I did not brought in Crane.\n5 Q. Withdrawn. That's why G/Clubs brought in Crane, right?\n6 A. I'm not exactly sure the reason.\n7 Q. Remember you were shown a picture of Haitham Khaled on\n8 direct?\n9 A. Yes.\n10 Q. Do you have an opinion about his character for\n11 truthfulness?\n12 MR. FINKEL: Objection.\n13 THE COURT: So if you'll step up, please.\n14 (Continued on next page)\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 (At the sidebar)\n2 THE COURT: So you need to lay a foundation if you're\n3 going to ask about character.\n4 MR. KAMARAJU: Just to be clear for the record, I'm\n5 relying on 608(a). The witness's credibility may be attacked\n6 if supported by testimony about the witness's reputation for\n7 having a character for truthfulness or untruthfulness.\n8 MR. FINKEL: When is the character been attacked?\n9 MR. KAMARAJU: It says may be attacked.\n10 MR. FINKEL: The last sentence. Evidence of truthful\n11 character is admissible only after the witness's character for\n12 truthfulness has been attacked.\n13 MR. KAMARAJU: Ms. Shroff extensively attacked his\n14 character.\n15 MS. SHROFF: I attacked his character.\n16 THE COURT: You've got to establish how she knows his\n17 reputation.\n18 MR. KAMARAJU: Fair enough.\n19 (Continued on next page)\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 (In open court; jury present)\n2 BY MR. KAMARAJU:\n3 Q. I'm going to withdraw that last question and ask you this.\n4 Did you have interactions with Mr. Khaled while you were at\n5 G/Club?\n6 A. Yes.\n7 Q. What were those interactions?\n8 A. He was looking at the very beginning for business office\n9 space and in charge of banking.\n10 Q. And was he involved in G/Club's dispute with Crane?\n11 A. He was, yes.\n12 Q. And as a result of your interactions with Mr. Khaled, did\n13 you develop a view as to his character for truthfulness?\n14 THE COURT: You need to lay a foundation with respect\n15 to reputation, and reputation is developed by speaking with\n16 others.\n17 Q. Did you ever speak with others about Mr. Khaled's\n18 reputation for truthfulness?\n19 A. If I spoke with other people if Mr. Khaled was truthful?\n20 Q. Yes.\n21 A. I don't remember.\n22 Q. That's your answer. You don't remember. Okay.\n23 Was your understanding that Crane was holding onto\n24 money that G/Club wanted to be processed, correct?\n25 A. Crane had G/Club money.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. Crane had G/Club money, right?\n2 A. Yes.\n3 Q. And G/Club wanted that money back, right?\n4 A. We wanted the money, yes.\n5 Q. At the time that Crane was holding onto the money, G/Clubs\n6 had access to other money, right?\n7 A. Could you repeat that.\n8 Q. Sure. At the time that Crane was holding onto the money,\n9 G/Clubs had access to other funds, right?\n10 A. Depending on the time because there were times that we had\n11 banking issues.\n12 Q. During the period of the dispute with Crane, did your\n13 salary ever go unpaid?\n14 A. No.\n15 Q. Are you aware of any employee's salary being unpaid at this\n16 time?\n17 A. No.\n18 Q. Did you continue to work to obtain benefits during the\n19 Crane's dispute?\n20 A. Yes.\n21 Q. So G/Clubs operation were continuing during the time of the\n22 Crane dispute, correct?\n23 A. Yes.\n24 Q. And it was funding those operations with money outside of\n25 Crane's control, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. Yes.\n2 Q. Now, you testified on direct that you gave some untruthful\n3 answers during that arbitration, right?\n4 A. Yes.\n5 Q. When did you first realize that you had given inaccurate\n6 answers in the arbitration?\n7 A. After I read the transcript.\n8 Q. When was that?\n9 A. When I was with my attorneys.\n10 Q. I just want to make sure. Your personal attorneys?\n11 A. Yes.\n12 Q. Again, I don't want you to tell me anything, but I believe\n13 you testified on direct that your personal attorneys, you\n14 retain your personal attorneys after Mr. Guo's arrest, correct?\n15 A. Yes.\n16 Q. So when did you first realize that you had made inaccurate\n17 statements in the arbitration, before or after you first met\n18 with the prosecutors?\n19 A. Before.\n20 Q. Say that again.\n21 A. The question is if I --\n22 Q. Let me try to rephrase it. Let me see if I can break it\n23 down.\n24 You first met with the prosecutors in this case, the\n25 folks at this table in August of 2023, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. I don't recall the date.\n2 Q. Was it several months after the arrest?\n3 A. It was after, yes.\n4 Q. It wasn't weeks after, right?\n5 A. No.\n6 Q. It was months after, right?\n7 A. Yes.\n8 Q. And did you realize you had given inaccurate answers in the\n9 arbitration during that period between Mr. Guo's arrest and\n10 your first meeting with the prosecutors?\n11 A. Yes, while I was reviewing with my attorneys.\n12 Q. Okay. Now, during your first meeting with the prosecutors,\n13 you didn't tell them that you had given inaccurate answers in\n14 the arbitration, did you?\n15 A. Could you repeat that.\n16 Q. In your first meeting with the prosecutors, you did not\n17 tell them that you had given inaccurate or misleading answers\n18 during the arbitration?\n19 A. I don't remember what I said during that first meeting.\n20 Q. In fact, the issue about you giving misleading answers in\n21 the arbitration was first raised by the prosecutors after your\n22 first meeting with them, correct?\n23 A. I don't recall that.\n24 Q. And your lawyer had multiple meetings with the prosecutors\n25 about that subject, correct?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. I'm not sure what my lawyers said on those meetings.\n2 Q. Your lawyers are in the room, right?\n3 A. Yes.\n4 Q. Your lawyers have a habit of going off on their own?\n5 MR. FINKEL: Objection.\n6 THE COURT: Sustained.\n7 Q. When did you first tell the prosecutors about it then?\n8 A. I don't remember specifically when.\n9 Q. How many times did you meet with the prosecutors?\n10 A. I don't know exactly how many times. As I said, more than\n11 ten.\n12 Q. More than ten?\n13 A. Yes.\n14 Q. So if we split ten in half, was it during the first five or\n15 the second five?\n16 MR. FINKEL: Asked and answered.\n17 THE COURT: Overruled. You may answer.\n18 A. I'm not exactly sure, maybe the first five.\n19 Q. But you don't recall specifically which one?\n20 MR. FINKEL: Asked and answered.\n21 THE COURT: Sustained.\n22 Q. You testified previously -- withdrawn.\n23 It was several meetings before you got a\n24 non-prosecution agreement, right?\n25 A. There were a few meetings before, yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. More than ten?\n2 A. No, I don't believe that.\n3 Q. But you spoke with the prosecutors about your supposedly\n4 misleading answers during the arbitration prior to getting a\n5 non-prosecution agreement, right?\n6 A. I believe so, yes.\n7 Q. And in fact you had a meeting with the prosecutors where\n8 your lawyer ask you to leave the room, right?\n9 A. When specifically?\n10 Q. I'm just asking do you remember any meeting like that?\n11 A. That I was asked to leave the room?\n12 Q. Yes.\n13 A. Yes.\n14 Q. Were there more than one meeting like that?\n15 A. I believe so.\n16 Q. And what was your understanding as to why you were being\n17 asked to leave the room?\n18 A. My attorneys would be talking to the government.\n19 Q. What was your understanding of what they would be\n20 discussing with the government?\n21 A. I don't remember specifically what the topics were at the\n22 time.\n23 Q. So your testimony, ma'am, is that you don't remember\n24 sitting here today what your lawyers were going to talk to the\n25 prosecutors about, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 MR. FINKEL: Asked and answered.\n2 THE COURT: Sustained.\n3 Q. Do you remember when you signed your non-prosecution\n4 agreement?\n5 A. A few months back.\n6 Q. I'm sorry.\n7 A. A few months back.\n8 Q. So this year?\n9 A. Yes.\n10 Q. Do you remember if you had told them about your misleading\n11 statements in the arbitration last year?\n12 MR. FINKEL: I think this has been asked and answered.\n13 THE COURT: I'm going to allow this question.\n14 Q. Do you remember?\n15 A. To the best of my recollection, yes.\n16 Q. So you told them last year, right?\n17 MR. FINKEL: Asked and answered. We keep circling\n18 this.\n19 THE COURT: Sustained.\n20 Q. I'd like to show you -- if can we pull up just for the\n21 witness, the Court and the parties 3533-010. Can we blow that\n22 up for the witness, the paragraph that starts at August 1st.\n23 A. Yes.\n24 Q. You had a second to look that over?\n25 A. Yes.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. Does looking at this refresh your recollection as of the\n2 first date your meeting with the prosecutors was?\n3 A. I'm not exactly sure.\n4 Q. Meeting with the U.S. Attorney's office for the Southern\n5 District of New York is a pretty memorable event, right?\n6 A. Yes.\n7 Q. Prior to meeting these folks at this table, have you ever\n8 met with a prosecutor before?\n9 A. No.\n10 Q. You were pretty scared when you sat down with them, right?\n11 A. Pretty nervous.\n12 Q. Because you were worried they might think you had done\n13 something wrong, right?\n14 A. I was worried.\n15 Q. Okay. Worried about what?\n16 A. About their views.\n17 Q. Their views about what?\n18 A. My time at G/Clubs.\n19 Q. And what were you -- withdrawn.\n20 What were you worried about might happen about your\n21 time at G/Clubs?\n22 A. Can you repeat that.\n23 Q. Let me ask it a different way. Why would you care what the\n24 people sitting at this table thought about your work at G/Club?\n25 A. I could get charged of a crime.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. And you were worried about that, right?\n2 MR. FINKEL: Asked and answered.\n3 THE COURT: Sustained.\n4 Q. That's why you sat down with them, right, cause you were\n5 worried about being charged? You went to speak to the\n6 prosecutors?\n7 MR. FINKEL: Asked and answered.\n8 THE COURT: Sustained.\n9 Q. And when you spoke with them, you had a lawyer, right?\n10 A. Yes.\n11 Q. And over the course of several meetings, you explained to\n12 them about your time at G/Clubs, right?\n13 A. Yes.\n14 Q. And you testified on direct that you didn't believe you had\n15 committed any crimes while you were at G/Clubs, right?\n16 A. Correct.\n17 Q. But you were still worried that they may charge you with a\n18 crime, right?\n19 A. Yes.\n20 Q. So you were trying to get a way out of that, right?\n21 A. No.\n22 Q. Well, that's why you met with them to avoid being charged,\n23 right?\n24 MR. FINKEL: Asked and answered.\n25 THE COURT: Sustained.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. So when you met with them, did you tell them that you were\n2 afraid of being charged?\n3 A. I don't recall.\n4 Q. Did they tell you that you might have the prospect of being\n5 charged?\n6 A. Could you repeat that.\n7 Q. Did any of the folks sitting at this table right here tell\n8 you during any of your more than ten meetings with them that\n9 you might be facing criminal charges in connection with your\n10 time at G/Clubs?\n11 A. I'm not exactly sure. I believe I could be charged with\n12 criminal charges.\n13 Q. Could you say that first part again.\n14 A. I don't remember a conversation, but I was aware I could be\n15 charged.\n16 Q. It would be pretty frightening to hear from a federal\n17 prosecutor that you might be charged with a crime, right?\n18 MR. FINKEL: Objection.\n19 THE COURT: Asked and answered.\n20 Q. Now ultimately you secured a non-prosecution agreement,\n21 correct?\n22 A. I was provided a non-prosecution agreement.\n23 Q. And you signed it, right?\n24 A. Yes.\n25 Q. And your lawyer signed it?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. Yes.\n2 Q. And one of the people sitting at this table signed it?\n3 A. Yes.\n4 Q. Why don't we take a look at it. Could we pull up I guess\n5 it's marked GX3533-50. You recognize this document?\n6 A. Yes.\n7 Q. Can we flip to the last page, please. That's your\n8 signature?\n9 A. Yes.\n10 Q. That's your lawyer's signature?\n11 A. Yes.\n12 Q. You signed it just a couple of months ago, right?\n13 A. Yes.\n14 MR. KAMARAJU: The defense offers GX-3533-50.\n15 MR. FINKEL: No objection. I don't think it has a GX.\n16 It's just 3533-50.\n17 THE COURT: It is admitted.\n18 MR. KAMARAJU: We can give it a defense number at the\n19 end of the day.\n20 (Government's Exhibit 3533-50 received in evidence)\n21 BY MR. KAMARAJU:\n22 Q. Can we publish that, please. Let's scroll down to the\n23 first paragraph. Could you read the first paragraph?\n24 A. On the understandings specified below, the office of the\n25 United States attorney for the Southern District of New York\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 will not criminally prosecute Limarie Reyes Molinaris for any\n2 crimes, except for criminal tax violation, if any, as to which\n3 this office cannot and does not make any agreement related to\n4 any and all actions taken in connection with her employment at\n5 G/Clubs and its related entities from in or about December 2020\n6 through on or about March 23, 2023 to the extent Reyes has\n7 disclosed such conduct to this office as of the date of this\n8 agreement.\n9 Q. What's your understanding as to the scope of protection\n10 from criminal prosecution that you enjoy right now?\n11 A. As long as I tell the truth, I will not be charged.\n12 Q. Let's pull that down for a second, not the whole document,\n13 just zoom back out to the bigger one. Let's go to the next\n14 paragraph.\n15 You see the paragraph starts, Moreover. Can you read\n16 that first sentence?\n17 A. Moreover, if Reyes fully complies with the understanding\n18 specified in this agreement, no testimony or other information\n19 given by her or any other information directly or indirectly\n20 derived therefrom will be used against her in any criminal tax\n21 prosecution. This agreement does not provide any protection\n22 against prosecution for any crimes except as set forth above.\n23 Q. And you testified on direct that you, under this agreement,\n24 you have an obligation to testify truthfully, correct?\n25 A. Correct.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. And if you don't testify truthfully, then this agreement\n2 could be null and void, right?\n3 A. Yes.\n4 Q. It's the government that decides if you testify truthfully,\n5 right?\n6 A. No.\n7 Q. Who decides?\n8 A. I do.\n9 Q. You do?\n10 A. Yes.\n11 Q. So if you decide that you testified truthfully and the\n12 government disagrees, what happens to your agreement?\n13 A. It gets nulled.\n14 Q. Sorry.\n15 A. It gets canceled.\n16 Q. So they decide, right?\n17 A. I decide to tell the truth.\n18 Q. Sure. And they decide if it's actually the truth?\n19 A. They decide if I'm telling the truth.\n20 Q. Now, there have been times during your meetings with them\n21 where they have chastised you for not telling the truth,\n22 correct?\n23 MR. FINKEL: Objection.\n24 THE COURT: Overruled. You may answer.\n25 A. Could you repeat the question.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. There have been times during your meetings with them where\n2 they have chastised you for not telling the truth, right?\n3 A. What does chastise?\n4 THE COURT: Did they scold you.\n5 THE WITNESS: Could you explain scold?\n6 Q. Well, okay. During a meeting with the prosecutors,\n7 Mr. Finkel told you that he didn't think you were telling the\n8 truth and reminded you of your obligation under your proffer\n9 agreement, correct?\n10 A. Could you repeat that.\n11 Q. I'll ask the court reporter to read it back, please.\n12 (Record was read)\n13 A. No, I do not recall that.\n14 Q. And you're aware, are you not, that Mr. Horton told your\n15 lawyer that they didn't think you were telling the truth about\n16 the arbitration testimony, right, the gentleman with the beard\n17 right there?\n18 A. I don't remember.\n19 Q. Could we pull up just for the witness 3533-0303. If you\n20 could read that to yourself, please.\n21 MR. FINKEL: Is there a question?\n22 MR. KAMARAJU: She's reviewing the document.\n23 A. Yes.\n24 Q. Does looking at this document refresh your recollection as\n25 to whether Mr. Horton ever told your lawyers that they thought\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 you were not being truthful about your arbitration testimony?\n2 MR. FINKEL: Objection this document.\n3 THE COURT: The question is whether this document\n4 refreshes her recollection. That's the question. You may\n5 answer.\n6 A. I don't remember Mr. Horton.\n7 Q. Okay. We could take it down.\n8 Now, you testified that G/Clubs had retained a lawyer\n9 named Aaron Mitchell, correct?\n10 A. Yes.\n11 Q. And that was in connection with the Crane situation?\n12 A. Yes.\n13 Q. Now, on direct you testified that money that was used to\n14 buy to the Bugatti, sorry that was used to buy the Bugatti came\n15 from G/Clubs members' payments, right?\n16 A. Monies for G/Clubs came from member payments.\n17 Q. But you testified specifically that the Bugatti payment\n18 came from that, right?\n19 A. Monies came from member payments.\n20 Q. Do you not remember testifying to that just a little while\n21 ago?\n22 MR. FINKEL: Asked and answered.\n23 THE COURT: Sustained.\n24 Q. All right. Do you remember testifying that the Lamborghini\n25 was purchased with money from G/Clubs members' payments?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. Money were received from member payments.\n2 Q. What about the camper van, do you remember testifying just\n3 a little while ago that that was purchased using money from\n4 G/Clubs member payments?\n5 A. Money was received from member payments.\n6 Q. You testified that you received a salary at G/Clubs, right?\n7 A. Yes.\n8 Q. Was that paid for using money from G/Clubs member payments?\n9 A. It was to payroll.\n10 Q. I'm sorry.\n11 A. It was through payroll and monies came from members\n12 payments.\n13 Q. Now, you also testified that you got a discretionary bonus,\n14 right?\n15 A. What do you mean a discretionary bonus, the yearly bonus?\n16 Q. I'm not referring to the Puerto Rican Christmas bonus, but\n17 the other one?\n18 A. Yes.\n19 Q. The money for that bonus came from the proceeds of the sale\n20 of G/Clubs memberships, right?\n21 A. I do not know where those funds came from.\n22 Q. How else did G/Clubs make money?\n23 A. Member payment.\n24 Q. If it didn't come from there, where did it come from?\n25 A. I do not know.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 Q. How about the money you spent on G Talks, did that come\n2 from the proceeds of sales of G/Club memberships?\n3 A. Could you repeat that.\n4 Q. You testified on direct that you spent money on G Talks,\n5 right?\n6 A. Yes.\n7 Q. The money you spent on G Talks, did that come from the\n8 proceeds of the sale of G/Club memberships?\n9 A. Monies were from member payments, correct.\n10 Q. Now, you testified on direct the payments -- the member\n11 payments, to use your reference, that didn't entitle G/Club\n12 members to any stock in the company, right?\n13 A. Correct.\n14 Q. They weren't making an investment into the company, right?\n15 A. No.\n16 Q. You didn't check with the members about whether you should\n17 get a bonus, right?\n18 A. No, I did not.\n19 Q. Because it wasn't their business, right?\n20 A. I don't believe so.\n21 Q. G/Clubs could decide to give you a bonus, right?\n22 A. The bonus was provided by Yvette.\n23 Q. Sorry.\n24 A. The bonus was provided by Yvette.\n25 Q. Yvette paid you personally?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Cross\n1 A. She approved.\n2 Q. And where did the money come from?\n3 A. I'm not sure.\n4 Q. You didn't clear your salary with the members, right?\n5 A. Did I clear?\n6 Q. You didn't ask the members if it was okay to get a salary,\n7 right?\n8 A. No.\n9 Q. Even though your salary was coming from the member\n10 payments, right?\n11 A. Correct. It was our operations.\n12 Q. Cause the member payments were G/Club's revenue, right?\n13 A. Yes.\n14 Q. It's no different than your company Sprinkle, right? Let\n15 me break it down.\n16 Your company is an event planning business, your\n17 current one?\n18 A. Yes.\n19 Q. You plan events for people, right?\n20 A. Yes.\n21 Q. They pay you money to do it, right?\n22 A. Yes.\n23 Q. You're the owner of the business, right?\n24 A. Yes.\n25 Q. You then decide how to spend that money, right?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 A. Yes.\n2 Q. Haoran He was the owner of G/Clubs, right?\n3 A. Yes.\n4 Q. So it's his decision how to spend that money, right?\n5 A. Yes.\n6 Q. It's his decision if he wants to buy a Ferrari, right?\n7 MR. FINKEL: Objection.\n8 THE COURT: You may answer.\n9 A. He provide instructions.\n10 Q. His decision if he wants to buy a Lamborghini, right?\n11 A. He provided the instructions for us to execute.\n12 Q. His decision if he wants to buy a mansion in New Jersey,\n13 right?\n14 A. I'm not aware of that.\n15 Q. His decision if he wants to make an investment in Hamilton,\n16 right?\n17 A. His instructions.\n18 Q. None of that has anything to do with the G/Clubs members,\n19 right?\n20 MR. FINKEL: Objection, asked and answered.\n21 THE COURT: Sustained.\n22 MR. KAMARAJU: No further questions.\n23 THE COURT: Redirect.\n24 REDIRECT EXAMINATION\n25 BY MR. FINKEL:\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 Q. Ms. Reyes, at Sprinkle Events do you promise that your\n2 clients will receive stock in Sprinkles?\n3 A. No, I did not.\n4 Q. You were asked other places you worked at. Do you remember\n5 those questions?\n6 A. Yes.\n7 Q. Did any of the other places you worked at send $5 million\n8 to Kyrgyzstan after their money was seized by the United States\n9 government?\n10 A. No.\n11 Q. You were asked some questions about G/Clubs benefits, were\n12 you a member of G/Club?\n13 A. No, I was not.\n14 Q. Did you recommend to your friends that they should become\n15 members of G/Club?\n16 A. No, I did not.\n17 Q. Did you recommend to your family members that they should\n18 purchase a membership in this G/Club that you were working at?\n19 A. No, I did not.\n20 Q. If we can pull up SH-150, please.\n21 When you went to the Sherry-Netherland, did Miles Guo\n22 show you these pens?\n23 A. I don't recall seeing this.\n24 Q. We can take that down. Refund request -- withdrawn.\n25 Member complaints, were there complaints from members\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 throughout your time period at G/Club?\n2 A. Yes.\n3 Q. What were the nature of those complaints?\n4 A. They were different, refund request, and amongst those\n5 different reasons.\n6 Q. What were the reasons that members sought refund request?\n7 A. They thought it was investment, not having enough benefit.\n8 Q. Did that happen through your whole period at G/Clubs?\n9 A. I recall specific time period.\n10 Q. Did it happen when you were CEO?\n11 A. Yes.\n12 Q. When did you become CEO?\n13 A. Summer 2021.\n14 Q. The hotels that defense counsel showed you on cross\n15 examination that you saw in London, did that hotel company\n16 engage with G/Club?\n17 A. No, they did not.\n18 Q. Whose idea was it to -- withdrawn. Did Alex H tell you\n19 that the loans were not repaid?\n20 MR. KAMARAJU: Objection, hearsay.\n21 THE COURT: Overruled. You may answer.\n22 MR. FINKEL: Withdrawn.\n23 Q. Did Alex H tell you that the loan to BVI and other entities\n24 were being repaid?\n25 MR. KAMARAJU: Same objection.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 THE COURT: You may answer.\n2 A. They were not being paid.\n3 Q. They were not being paid?\n4 A. Correct.\n5 Q. That's what Alex told you?\n6 A. They had not been paid.\n7 Q. If we could pull up GC-157, please. You remember being\n8 asked some questions about what would happen when a member's\n9 payments weren't made and their membership would lapse?\n10 A. Could you repeat that, please.\n11 Q. Ms. Loftus, can you zoom in on the bottom.\n12 Can you read this email from Alex H to you on June 28,\n13 2021, beginning with, Attach you will find.\n14 A. Attach you will find spreadsheet that James was kind enough\n15 to organize for us containing breakdown of all the square\n16 transactions paid unpaid. I believe we have extended a long\n17 enough grace period for members to repay and keep their\n18 memberships. As controller it is my recommendation we cancel\n19 and void all outstanding memberships that have not been repaid.\n20 I simply wanted to run this by you first so we are in\n21 agreement. I have discussed this with Yvette yesterday.\n22 Q. What ask your understanding of why Alex discussed this\n23 issue with Yvette?\n24 MR. KAMARAJU: Objection.\n25 THE COURT: Overruled.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 A. She would be asked about different topics of the business.\n2 Q. Where did Yvette work?\n3 A. New York.\n4 Q. If we can pull up GXGC-175. These emails that you sent to\n5 Mr. He like this one containing the loan documentation or asset\n6 documentation, the body of the email, how did you write it?\n7 A. It was like an extract from the different documents.\n8 THE COURT: Did you mean excerpt?\n9 THE WITNESS: Like I extracted.\n10 THE COURT: Extracts you're saying?\n11 THE WITNESS: I extracted word from the loan\n12 documents.\n13 Q. When did you meet Mileson, what year?\n14 A. 2021.\n15 Q. How long did you meet with him for?\n16 A. Just for that dinner.\n17 Q. How long was that dinner?\n18 A. Couple of hours.\n19 Q. That's the only time you saw him?\n20 A. Yes.\n21 Q. Do you see on your screen HN-28?\n22 A. Yes.\n23 Q. You see date of issue at the bottom left?\n24 A. Yes.\n25 Q. What's the date of issue?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 A. November 3, 2014.\n2 Q. So seven years before you saw Mileson on the boat?\n3 A. Yes.\n4 Q. You can take that down. You can pull up GXGC-93. This is\n5 an email from you, is that correct, to Yvette?\n6 A. Yes.\n7 Q. And can you read the first sentence after Dear Yvette?\n8 A. Please find attached the design options for G/Club member\n9 physical card and packaging for your review and Mr. Guo's\n10 feedback.\n11 Q. Why did you send an email to Yvette seeking Mr. Guo's\n12 feedback?\n13 A. I was told that the original designs had been reviewed by\n14 him and there was an interest to have a titanium physical card.\n15 Q. But why did you send it to Yvette seeking Mr. Guo's\n16 feedback?\n17 MR. KAMARAJU: Asked and answered.\n18 THE COURT: Overruled. You may answer.\n19 A. I would seek Yvette's approval in different matters.\n20 Q. You say for your review and Mr. Guo's feedback. This email\n21 is not sent to Mr. Guo. Why did you send it to Yvette seeking\n22 Mr. Guo's feedback?\n23 MR. KAMARAJU: Same objection.\n24 THE COURT: Sustained.\n25 Q. If we could put up GC-541. You remember you were asked\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 some questions about Mr. Guo's consulting agreement?\n2 A. Yes.\n3 Q. And it's dated October 15, 2020 at the top?\n4 A. Yes.\n5 Q. Go to the next page, please, Ms. Loftus.\n6 You see where it says consideration?\n7 A. Yes.\n8 Q. It says level five membership?\n9 A. Yes.\n10 Q. Does it say red Lambo Aventador?\n11 A. No.\n12 Q. Does it say Bugatti?\n13 A. No.\n14 Q. Does it say $10 million for my son?\n15 A. No.\n16 Q. Does is say a house that cost $26 million in Mahwah, New\n17 Jersey?\n18 MR. KAMARAJU: Object to form.\n19 THE COURT: Overruled. You may answer.\n20 A. No.\n21 Q. Go back to the first page, Ms. Loftus. And this is October\n22 15, 2020, correct?\n23 A. Yes.\n24 Q. Can we pull up Z9 and go to page 57. This is October 13,\n25 2020, you see that in the left corner?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 A. Yes.\n2 Q. Can you scroll down a little bit, Ms. Loftus.\n3 You remember being asked to read pieces of this during\n4 cross examination?\n5 A. Yes.\n6 Q. Scroll down a little bit. And you read how Guo had said\n7 that you don't get stock in G/Clubs. That was the segment that\n8 you were asked to read. Do you recall that?\n9 A. Yes.\n10 Q. Can you read the last paragraph at the bottom of page 58.\n11 A. To put it bluntly, this is all non-sense. I'll be straight\n12 forward with you. This is what we need to have to legally\n13 avoid Me Too, but don't think that we are being mingy here.\n14 There is no other way. We'd have to have that.\n15 Q. Go to page 101 of this document, please.\n16 Who is that a picture of?\n17 A. Mr. Guo.\n18 Q. And what's the date on the left?\n19 A. June 23, 2021.\n20 Q. Can you scroll down, please. Can you read that bottom\n21 paragraph?\n22 A. A couple of days ago our G/Club president Limarie who has a\n23 very tiny face in real life, gorgeous, came to New York for\n24 meetings. Our Limarie and Wen Xiao also interviewed brother\n25 seven about the future planning of the G/Club.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 Q. You can stop right there. Can you zoom out of that,\n2 Ms. Loftus, and can you scroll down a little bit. Can you zoom\n3 in on the paragraph that says a month ago. Can you read\n4 beginning of where it says then I proposed?\n5 A. Then I proposed a condition to allow our G/Club members to\n6 buy their car at the best price in the world. They said that\n7 they would discuss it again, and we'll have to wait a little\n8 longer. Think about the G/Club membership now. You know that\n9 back then it was purchased in two tiers. 10,000 U.S.D and\n10 50,000 U.S.D. Now for those of you who bought the tier of\n11 10,000 U.S.D, you have a 1,000 shares. And for those of you\n12 who bought the tier of 50,000, U.S.D. and you have 500,000\n13 shares and then you have a lifetime access to the card.\n14 There's nothing else I can say.\n15 Q. Ms. Reyes, when someone bought a $10,000 membership in\n16 G/Clubs, did they get a 100,000 shares?\n17 A. Not that I was not aware of.\n18 Q. We can zoom out of that and please go to page 111. Can you\n19 scroll up a little bit please, Ms. Loftus.\n20 Who is that a picture of?\n21 A. Mr. Guo.\n22 Q. Can you scroll down to 114, please, Ms. Loftus. Can you\n23 start reading from, We will have all investors.\n24 A. We will have all investors in G/Club, all investors now who\n25 are currently set at 50,000. When paying $50,000 for the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Recross\n1 membership card, you will have 10,000 shares of G Fashion in\n2 the future. At the time of the IPO, you'll have 10,000 shares\n3 of G Fashion, but then these days there are so many fellow\n4 fighters sending me messages. They all express their wishes\n5 saying, Mr. Guo, I only have 30,000, can I buy a G/Club card.\n6 Yes. I have 40,000, can I buy G/Club card? Yes. But I've\n7 been thinking, the people who haven't spent 50,000, can they\n8 get 10,000 shares? It's like giving them 10,000 shares for\n9 free, right? I mean that when it goes public, you have to pay\n10 a dollar per share for 10,000 shares, it's $10,000.\n11 But think about it, those who pay $40,000 or $30,000\n12 won't be allocated shares which is not fair. The poorer the\n13 fellow fighters, the more care we have to render, right? This\n14 is not good. This is not good at all. So I was thinking how\n15 to get this fellow fighters to own the shares, which is the\n16 only question.\n17 Q. You can stop right there.\n18 Ms. Reyes, did you refer to G/Clubs members as\n19 investors?\n20 A. No.\n21 MR. FINKEL: Nothing further.\n22 MR. KAMARAJU: I can be done in two minutes.\n23 THE COURT: Okay. Go ahead.\n24 RECROSS EXAMINATION\n25 BY MR. KAMARAJU:\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 Q. Do you remember Mr. Finkel asked you if you recommended\n2 G/Clubs to any of your friends?\n3 A. Yes.\n4 Q. Are any of your friends high net worth Chinese individuals?\n5 A. No.\n6 Q. Are any of your friends active in Chinese politics?\n7 A. No.\n8 Q. Are any of your friends anti-CCP?\n9 A. No.\n10 MR. KAMARAJU: I'm done. Thank you, your Honor.\n11 REDIRECT EXAMINATION\n12 BY MR. FINKEL:\n13 Q. The hotels in Puerto Rico that you were asked about, do\n14 those hotels have anything to do with the Chinese Communist\n15 Party.\n16 A. No.\n17 MR. FINKEL: Nothing further.\n18 THE COURT: You may step out.\n19 (Witness excused)\n20 THE COURT: Members of the jury, the good news is that\n21 we have ended for the day and you have tomorrow off. You will\n22 be returning on Thursday ready to walk into the courtroom at\n23 9:30. Remember that you're not allowed to talk about the case\n24 amongst yourselves or with anyone else. Don't permit anyone to\n25 talk about the case in your presence. Don't read, listen or\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 watch anything from any source having to do with the subject\n2 matter of this case. Have a good day off.\n3 THE LAW CLERK: Jury exiting.\n4 (Jury not present)\n5 (Continued on next page)\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 (Jury not present)\n2 THE COURT: Please be seated. Is there anything\n3 before we resume on Thursday morning?\n4 MR. FINKEL: Your Honor, just briefly, and this may\n5 come up with other witnesses. The reason I objected regarding\n6 the disclaimer in the membership agreement pertains to your\n7 Honor's ruling. Your Honor decided that it is proper and fair\n8 for the defense to question victims about whether the\n9 disclaimers made representations by the defendant not material,\n10 or sort of seek to underline the materiality of what the\n11 defendant said. Your Honor's ruled on that. Ms. Reyes did not\n12 invest in G/Clubs. She did not invest in any of Guo's\n13 investment offerings. For that reason, it occurred to us that\n14 based on your Honor's ruling, it would be improper to suggest\n15 to the jury that, as your Honor put it, there's a fine line\n16 between properly asking about an investor's sophistication and\n17 improperly implying to the jury that the investor should have\n18 found out the truth about the alleged misrepresentations.\n19 Which is to say that by Mr. Guo saying in videos that he was\n20 offering stock, if the investor, member, or victim went to the\n21 website and saw the disclaimer, they should have known this was\n22 fine.\n23 Mr. Reyes being used as a vehicle to sort of plaster\n24 the disclaimer, the government views as improper and in\n25 contrary to your Honor's ruling. That ship has sailed. But in\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 an appropriate time and if this comes up again, I expect that\n2 we'll ask for some sort of instruction, cause the government is\n3 concerned that the jury is confused about how to consider these\n4 disclaimers. And while it's fair for them to consider them as\n5 your Honor has already ruled as an issue of materiality for the\n6 victims, it's improper for them to consider it as a reason why\n7 victims should not have been defrauded, and that was the reason\n8 for my objection.\n9 THE COURT: But are you saying that only a victim can\n10 be questioned about these disclaimers? Are you saying that a\n11 non-victim should not be questioned about this?\n12 MR. FINKEL: I think it depends. Really the devil is\n13 in the details. The way the questions were posed to Ms. Reyes\n14 were just reading the disclaimer and saying in effect, and\n15 forgive me if I'm misquoting, the member saw this, member knew\n16 this, something to that effect. That's what I recall. I do\n17 think that's improper to Ms. Reyes. She can't speak to what\n18 members saw. I think the purpose of those questions was to\n19 plant a seed in the jury's mind that because the disclaimer is\n20 there, it renders -- it undermines the government's proof. As\n21 your Honor ruled, the disclaimer has a purpose in the\n22 consideration of the matters before them, it's a specific\n23 purpose. And so the government is concerned that the jury is\n24 confused about what that purpose is.\n25 MR. KAMARAJU: Your Honor, while I am sure that the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 government is concerned about evidence undermines its proof,\n2 the law is that materiality is determined by the totality of\n3 information available to the potential investors. That's TSC\n4 v. Basic Industries and U.S. v. Litvak. And that a jury is\n5 suppose to consider the totality of information in deciding\n6 whether a particular statement is material or not material for\n7 purposes of the securities law or the wire frauds statute.\n8 There is no ruling by the Court that I'm aware of that says\n9 that a witness cannot authenticate one of the disclaimers,\n10 which is what happened with Ms. Reyes. Your Honor gave a\n11 limiting instruction. Your Honor is going to give instructions\n12 as to the law which will clear up any confusion that the jury\n13 might have, especially since they're not supposed to be\n14 deliberating now anyway. And now this is the second or third\n15 time I believe that the government has now asked for this\n16 similar limiting instruction.\n17 So I would say that given that the jury is entitled to\n18 consider the total mix of information. And given that at least\n19 I don't believe I did anything to suggest that this was a\n20 reliance argument or ask Ms. Reyes any question about whether\n21 G/Clubs purchasers should be able to rely on the disclaimer, I\n22 don't think there's an issue, and I think your Honor ruling was\n23 correct. And it should come in the same way through other\n24 witnesses whether they're victims or non-victims.\n25 MR. FINKEL: Your Honor, first of all, a lot of what\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 defense counsel said, not all of it, but a lot of what defense\n2 counsel said is correct, but he avoided the issue that the\n3 government is complaining about. In the government's view, and\n4 this is reading from your Honor's ruling. This is docket 319\n5 at page 17. The government sought to preclude certain evidence\n6 and certain arguments because \"from arguing that victims were\n7 negligent or insufficiently vigilant.\" Meaning there should be\n8 no suggestion -- and this is the law, and defense counsel has\n9 not stated otherwise. The jury shouldn't think, oh, wait a\n10 second. They had the disclaimer on the website. And if Ming\n11 Yang Woo just went to the disclaimer and saw the disclaimer,\n12 this wouldn't have happened to her. It's her fault. And\n13 that's not the law. And that's defense counsel has not\n14 suggested otherwise.\n15 So while defense counsel is correct that the full mix\n16 of information maybe relevant to materiality, meaning the\n17 materiality of Guo's statements, it should not be used for an\n18 improper purpose. So the government's request for a\n19 instruction is consistent with what defense counsel just said\n20 which is to deliver to them the law so they know how to\n21 assimilate this information that's coming at them because they\n22 don't know.\n23 THE COURT: So my sense is that Mr. Kamaraju was\n24 merely pointing to the disclaimer, not making a reliance\n25 argument. And I will in the jury charge make very explicit\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nO6IBGUO5 Reyes - Redirect\n1 what the law is, and I think that that is adequate as oppose to\n2 a limiting instruction in the middle of the trial.\n3 MR. KAMARAJU: Thank you, your Honor.\n4 MR. FINKEL: Understood.\n5 THE COURT: Anything further?\n6 MR. KAMARAJU: Nothing from the defense, your Honor.\n7 MR. FINKEL: Nor the government, your Honor. See you\n8 on Thursday.\n9 (Adjourned to June 20, 2024 at 9:00 a.m.)\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\n1 INDEX OF EXAMINATION\n2 Examination of: Page\n3 LIMARIE REYES\n4 Direct By Mr. Finkel . . . . . . . . . . . . .3044\n5 Cross Q. . . . . . . . . . . . . . . . . . . .3151\n6 Redirect By Mr. Finkel . . . . . . . . . . . .3270\n7 Recross By Mr. Kamaraju . . . . . . . . . . .3279\n8 Redirect By Mr. Finkel . . . . . . . . . . . .3280\n9 GOVERNMENT EXHIBITS\n10 Exhibit No. Received\n11 GC-519, GC-523, GC-524, GC-529 GC-535, . . .3133\n12 GC-349, GC-373 and GC-177\n13 GC-41 . . . . . . . . . . . . . . . . . . .3138\n14 106 . . . . . . . . . . . . . . . . . . . .3059\n15 118 . . . . . . . . . . . . . . . . . . . .3059\n16 119 . . . . . . . . . . . . . . . . . . . .3082\n17 GC-232 . . . . . . . . . . . . . . . . . .3136\n18 GC-378 . . . . . . . . . . . . . . . . . .3135\n19 GC-515 . . . . . . . . . . . . . . . . . .3135\n20 GC-544 . . . . . . . . . . . . . . . . . .3122\n21 GC-544 . . . . . . . . . . . . . . . . . .3134\n22 GC551 . . . . . . . . . . . . . . . . . . .3099\n23 GC-552 . . . . . . . . . . . . . . . . . .3136\n24 3533-50 . . . . . . . . . . . . . . . . . .3262\n25 DEFENDANT EXHIBITS\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\n1 Exhibit No. Received\n2 20121 . . . . . . . . . . . . . . . . . . .3195\n3 20234 . . . . . . . . . . . . . . . . . . .3204\n4 20235 . . . . . . . . . . . . . . . . . . .3200\n5 60595 . . . . . . . . . . . . . . . . . . .3219\n6 60597 . . . . . . . . . . . . . . . . . . .3221\n7 60600 . . . . . . . . . . . . . . . . . . .3168\n8 60604 . . . . . . . . . . . . . . . . . . .3213\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300","body_zh":null,"key_entities":[],"ecf_references":[],"word_count":50583,"status":"published","published_at":"2024-07-23 00:00:00","created_at":"2024-07-23","updated_at":"2026-07-06 20:52:30"}