{"id":"court_sdny_516_0","court":"SDNY","case_no":"23-cr-00118","doc_number":516,"sub_number":0,"doc_type":"ORDER","filed_date":null,"title":"| UNITED STATES DISTRICT COURT<br>SOUTHERN DISTRICT OF NEW YORK<br><br>---------------------------------x<br>UNITED STAT","summary_zh":null,"summary_en":null,"body_en":"| UNITED STATES DISTRICT COURT<br>SOUTHERN DISTRICT OF NEW YORK<br><br>---------------------------------x<br>UNITED STATES OF AMERICA<br><br>- V.-<br><br>HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a<br>\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a<br>\"Brother Seven,\" a/k/a \"The Principal,\"<br>KIN MING JE, a/k/a \"William Je,\"and<br>YANPING WANG, a/k/a \"Yvette,\"<br>Defendants.<br><br>---------------------------------x | PETITION UNDER FED. R. CRIM. P. 32.2<br>AND 21 U.S.C. § 853(n) FOR ADJUDICATION<br>OF PETITIONER'S RIGHT TO SPECIFIC<br>PROPERTY OF<br>[\\$218,500.00] |\n|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------|\n|                                                                                                                                                                                                                                                                                                                                                                                                                      | S1 23 CR 118 (AT)                                                                                                                                     |\n\nI, Anne Lee (the Petitioner\"), pursuant to 21 U.S.C. § 853(n) and Rule 32.2(c) of the Federal Rules of Criminal Procedure, herby respectfully petitions the Court for a determination of Order of Forfeiture as to Specific Property/Money Judgment, signed by Your Honor on January 6, 2025 and entered on January 7, 2025, (the Forfeiture Order\") which includes various bank accounts ( Forfeited Accounts\"), Dkt. 488, to exclude all property in which\nthe Petitioner has right, title, and interest, namely, \\$218,500.00 (the Property\"). In support\nhereof, the Petitioner states as follows:\n\n- 1. Between 2020 to 2023, I, the Petitioner wired \\$218,500.00 in total to participate in the projects.\n- 2. I, the Petitioner transferred U.S. currency to the Forfeited Accounts as below :\n- 3. On October 20, 2020 Sent \\$20,000.00 via Order Number GC2010210105441 to G|CLUBS for Initial Membership Payment (G|CLUBS membership). Funds transferred into Account Number MBI10103-000 at Mercantile Bank International, held in the name of \"G Club International Ltd.\" and seized by the Government on or about October 16, 2022 (23-FBI-000287).\n- 4. On December 14, 2020 Sent \\$10,000.00 via Order Number HT2012142337301 to G|CLUBS for Initial Membership Payment. Funds transferred into Account Number MBI10103-000 and seized on October 16, 2022 (23-FBI-000287).\n- 5. On April 5, 2021 Sent \\$20,000.00 via Order Number JJ2104051745401 to G|CLUBS for Initial Membership Payment. Funds transferred into Account Number MBI10103- 000 and seized on October 16, 2022 (23-FBI-000287).\n- 6. On August 3, 2021 Sent a check for \\$50,000.00 via Order Number EE2108040002521 to G|CLUBS for Initial Membership Payment. Funds transferred into Account Number MBI10103-000 and seized on October 16, 2022 (23-FBI-000287).\n- 7. On December 14, 2021 Sent \\$2,500.00 via Order Number MU2112150331581 to G|CLUBS for Annual Membership Fee. Funds transferred into Account Number MBI10103-000 and seized on October 16, 2022 (23-FBI-000287).\n- 8. On October 7, 2022 Sent \\$2,500.00 via Order Number PS2210072158471 to G|CLUBS for Annual Membership Fee. Funds transferred into Account Number MBI10103-000 and seized on October 16, 2022 (23-FBI-000287).\n- 9. On November 30, 2022 Sent \\$2,500.00 via Order Number SP2212010337221 to G|CLUBS for Annual Membership Fee. Funds transferred into Account Number MBI10103-000 and seized on October 16, 2022 (23-FBI-000287).\n- 10. On January 26, 2022 Invested [\\$111,000.00] with Hamilton Opportunity Fund via bank transaction Number 13411144221. Funds transferred into account number 5090042770 at Silvergate Bank, held in the name of Hamilton Opportunity Fund SPC, and seized on September 18, 2022 (23-FBI-000074).\n\n| Transaction Type           | Wire<br>number                                                           | Total Amount                                 | Payment<br>Method       | Recipient                           | Asset ID      |\n|----------------------------|--------------------------------------------------------------------------|----------------------------------------------|-------------------------|-------------------------------------|---------------|\n| Membership                 | GC2010210105441<br>HT2012142337301<br>JJ2104051745401<br>EE2108040002521 | \\$20,000<br>\\$10,000<br>\\$20,000<br>\\$50,000 | Total 4 checks          | G-club                              | 23-FBI-000287 |\n| Annual Fee                 | MU2112150331581<br>PS2210072158471<br>SP2212010337221                    | \\$2500.00<br>\\$2500.00<br>\\$2500.00          | Check<br>Check<br>Check | G-club                              | 23-FBI-000287 |\n| Digital Bank<br>investment |                                                                          | \\$111,000                                    | Wire                    | Hamilton<br>Opportunity<br>Fund SPC | 23-FBI-000074 |\n\n- 11. I the petitioner never received any funds or investment back from the investments before they were seized by the government, having now suffered a total of unrecovered funds of my \\$218,500.00 investment.\n- 12. I, the petitioner, was not consulted prior to the entry of the Forfeiture Order. Petitioner had no knowledge that Defendant Wang consented to forfeit the Property. I invested in G|CLUBS and Hamilton Opportunity Fund to support the Whistleblower Movement which is led by Miles Guo. My family and I have experienced persecution by the CCP, and I believe that Mr. Guo is not lying; he is simply doing the right thing to take down the CCP.\n- 13. As an owner of the above listed assets, I, the petitioner has an interest in the Property which Defendant Wang had no authority to agree to forfeit. Rather, Petitioner has a superior interest in the Property which cannot be the subject of the Forfeiture Order relating to Defendant Wang.\n- 14. I was not involved in, nor did I have any knowledge of the Defendants' activities. Accordingly, I am also an innocent third party pursuant to 21 U.S.C. § 853(n). Any third party asserting a legal interest in property which has been ordered forfeited to the United States pursuant to this section may... petition the court for a hearing to adjudicate the validity of his alleged interest in the property.\" 21 U.S.C. § 853(n)(2). The petition, which is sworn and signed by the me, shall set forth the nature and extent of the petitioner s right, title, or interest in the property, the time and circumstances of the petitioner s acquisition of the right, title, or interest in the\n\nproperty, and additional facts supporting the petitioner's claim, and the relief\nsought.\" Id. § 853(n)(3).\n\n- 15. Here, I, the petitioner is the lawful owner of the Property.\n- 16. Alternatively, Petitioner is a bona fide purchaser for value of my interest in the Property under 21 U.S.C. § 853(n)(6)(B).\n- 17. Petitioner was made aware of the Order of Forfeiture by viewing it at www.forfeiture.gov (which was published from February 6, 2025 through March 7, 2025) noting that: pursuant to Title 21, United States Code, Section 835(n), persons other than the defendant who wish to assert a legal interest in property that has been ordered forfeited to the United States must file a petition for a hearing to adjudicate the validity of their alleged interest in the property with the Court within thirty (30) days of the final publication of notice, or receipt of actual notice, whichever is earlier.\"\n- 18. Petitioner has filed this petition within 60 days of the initial publication of notice.\n\n## WHEREFORE, Petitioner respectfully requests and petitions this Court:\n\na. to amend the Forfeiture Order to exclude the Property in which Petitioner has a rightful interest as an innocent third party, superior interest, and/or a bona fide purchaser for value.\n\n- b. A hearing pursuant to 21 U.S.C. § 853(n) on any disputed matters.\n- c. Compensation for the value of Petitioner's interest if the Petition is denied;\n- d. Any other relief the Court deems just and proper.\n\nDated: March 26, 2025\n\nRespectfully Submitted,\n\nAnne Lee\n\nIllegible Signature\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Signature\n\n## VERIFICATION\n\nI attest and declare under penalty of perjury that my petition is not frivolous, and the information provided in support of my petition is true and correct to the best of my knowledge and belief.\n\nExecuted on March 26, 2025, in New York City, New York, USA.\n\n## Anne Lee\n\n[Illegible Signature]\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Signature","body_zh":null,"key_entities":["853(n)","forfeiture","Guo","Je","Kwok","Miles Guo","CCP","CIPA","Ho Wan Kwok","Yanping Wang","Kin Ming Je","William Je","Rule 32.2"],"ecf_references":[{"doc_number":488,"court":"SDNY"}],"word_count":1127,"status":"published","published_at":null,"created_at":null,"updated_at":"2026-07-06 20:52:51"}