{"id":"court_sdny_830_0","court":"SDNY","case_no":"","doc_number":830,"sub_number":null,"doc_type":"DOC","filed_date":"2026-04-06","title":"SDNY ECF 830","summary_zh":null,"summary_en":null,"body_en":"1\n\nIN THE UNITED STATES DISTRICT COURT\nFOR THE SOUTHERN DISTRICT OF NEW YORK\n\nUNITED STATES OF AMERICA,\n\n                       -v-\n\nHO WAN KWOK, a/k/a   “Miles Guo,”\n“Miles Kwok,” “Guo Wengui,” “Brother\nSeven,” or  “The Principal,”\n\n                         and\n\nKIN MING JE, a/k/a “William Je,”\n\n                         and\n\nYANPING WANG, a/k/a “Yvette,”\n\n                                   Defendants.\n\n            Restitution of Seized Funds\n          Criminal No.:   23-cr-118 (AT)\n\nRESPONSE IN OPPOSITION TO\nZHUBEIBEI / BEIBEI ZHU’S\nSUPPLEMENTAL NOTICE OF\nVICTIM DAMAGES, OBJECTION TO\nPROCEDURAL FRAUD, AND\nMOTION FOR SANCTIONS; AND\nCROSS-MOTION FOR SANCTIONS\nUNDER COURT’s INHERENT\nAUTHORITY UNDER FED. R. CIV. P.\n11\n\n              Assigned to the Honorable U.S.\n              District Court Judge Analisa\n                  Torres, Presiding Judge\n\nRESPONSE IN OPPOSITION TO ZHUBEIBEI / BEIBEI ZHU’S SUPPLEMENTAL\nNOTICE OF VICTIM DAMAGES, OBJECTION TO PROCEDURAL FRAUD, AND\nMOTION FOR SANCTIONS; AND CROSS-MOTION FOR SANCTIONS PURSUANT\nTO FED. R. CIV. P. 11 AND THE COURT’S INHERENT AUTHORITY\n\nTO THE HONORABLE ANALISA TORRES, UNITED STATES DISTRICT JUDGE:\n\nUndersigned counsel, Bradford L. Geyer, respectfully submits this Response in\nOpposition to the frivolous, vexatious, and bad-faith “Supplemental Notice of Victim Damages,\nObjection to Procedural Fraud, and Motion for Sanctions” filed by Zhubeibei / Beibei Zhu on or\nabout March 21–22, 2026. This motion and subsequent letter motions filed through the pro se\nfiling system on March 26, April 2, April 4, and April 6, 2026, are recycled, meritless attacks\nthat was already rejected by this Court’s prior proceedings. It should be denied in full, stricken\n\n---\n\n2\n\nfrom the record, and met with sanctions against the movant for abuse of process and Rule 11\nviolations.\n\nI. PRELIMINARY STATEMENT\nThis is not a legitimate victim claim. It is a deliberate, bad-faith disruption tactic designed\nto harass undersigned counsel, smear legitimate victim advocacy, and delay restitution for\nthousands of bona fide Himalaya Exchange customers whose assets were seized by the\nGovernment. Movant voluntarily registered as a client on December 22, 2023, affirmatively\nconsented to representation, and was included in the sealed master roster. When she later\nobjected, counsel immediately terminated the relationship (see ECF 712). That should have\nended the matter.\n\nInstead, movant has launched a campaign of repetitive, inflammatory filings (ECF 709,\nnow this Supplemental Motion) that recycle the same debunked allegations while escalating\ndemands to half a million dollars in punitive damages. This is classic vexatious litigation. The\nmotion contains zero new evidence, relies on inflammatory rhetoric (“procedural predatory\nbehavior,” “administrative hijacking,” “secondary plunder”), and ignores the documented record.\nIt is an abuse of the Court’s process and should be met with sanctions.\n\nII. FACTUAL BACKGROUND\nMovant affirmatively consented to representation on December 22, 2023, at 9:20 a.m.,\nBeibei Zhu registered as a client of FormerFedsGroup.Com LLC and expressly requested\nrepresentation in connection with the seized Himalaya Exchange assets. She was added to the\n\n---\n\n3\n\nmaster client roster (filed under seal) and was one of the initial 3,345+ customers on whose\nbehalf the Rule 41(g) Motion for Return of Property was filed on December 6, 2023 (ECF 186).\nHer consent was written and voluntary.\n\nThe December 2023 motion protected victims — It did not “hijack” anything. The ECF\n186 motion (and supporting memorandum, ECF 186-1) was filed to return customer property\nseized by the Government. It was not an “inducement motion” or “false representation.” It was\nvictim advocacy filed in direct response to the Government’s forfeiture allegations. Movant’s\nclaim that counsel somehow “locked” her assets is a fabrication that ignores the procedural\nhistory and the Government’s independent seizure actions (see ECF 188, 189).\nCounsel Terminated Representation Upon Objection In June 2025, after movant filed her first\nmeritless motion (ECF 709), counsel promptly reviewed her file, confirmed the registration, and\nterminated the attorney-client relationship in the Response filed June 30, 2025 (ECF 712).\nMovant has been removed from all client lists and is free to represent herself or retain other\ncounsel. There is no ongoing representation, no retainer agreement in dispute, and no basis for\nany damages claim.\n\nIII. ARGUMENT\nA. The Motion Is Frivolous and Repetitive\nMovant’s claims of “false representation,” “perjury,” and “procedural fraud” are identical\nto those already addressed in ECF 709 and ECF 712. She offers no new evidence — no retainer\nagreement dispute, no proof of lack of consent, no documentation of any “hijacking.” Instead,\nshe recycles conspiracy-laden rhetoric and demands $500,000 in sanctions and damages without\n\n---\n\n4\n\nany legal or factual support. This violates Fed. R. Civ. P. 11(b)(1)–(3). The motion should be\ndenied outright.\n\nB. There Was No Unauthorized Representation — Movant Consented\nThe record is undisputed: movant registered, requested representation, and was treated\nexactly as every other consenting customer. Her sudden reversal months later does not\nretroactively create “fraud.” Counsel’s termination of the relationship in ECF 712 moots any\nclaim for ongoing harm.\n\nC. The Trustee and Government Actions Are Irrelevant to Counsel\nMovant’s attacks on Trustee Luc A. Despins and the Government’s forfeiture positions\n(ECF 188, 189) have nothing to do with undersigned counsel. Counsel did not file those\ndocuments, does not control the Trustee, and has no fiduciary duty to the bankruptcy estate.\nAttempting to drag counsel into a collateral dispute with the Trustee is a transparent attempt to\nmanufacture liability where none exists.\n\nD. This Filing Harms Legitimate Victims\nWhile movant files inflammatory supplemental motions demanding personal windfalls,\nover thousands of verified customers (and thousands more) wait for the return of their lawfully\nheld assets. This pattern of vexatious filings wastes Court resources and delays justice for real\nvictims. The Court’s inherent authority and Rule 11 exist precisely to deter such conduct.\n\n---\n\n5\n\nIV. CROSS-MOTION FOR SANCTIONS\nPursuant to Fed. R. Civ. P. 11(c) and the Court’s inherent authority (see Chambers v.\nNASCO, Inc., 501 U.S. 32 (1991)), undersigned counsel respectfully requests that the Court:\nStrike the Supplemental Motions in  their entirety as frivolous and vexatious;\n\nImpose monetary sanctions on movant Beibei Zhu / Zhubeibei in an amount the Court deems\nappropriate to deter future abuse;\n\nIssue a formal warning or pre-filing injunction against further repetitive, baseless filings in this\nmatter without leave of Court; and\n\nGrant such other relief as the Court deems just and proper.\n\nV. CONCLUSION\nThe Supplemental Motion is a meritless, bad-faith attack by a former client who\nvoluntarily sought representation, later changed her mind, and now seeks to punish counsel for\nperforming victim advocacy on behalf of thousands of others. It should be denied with prejudice,\nand sanctions should be imposed on the movant.\nDated:  April 6, 2026\n\nRESPECTFULLY SUBMITTED\n\n/s/ Brad Geyer\n\nBradford L. Geyer, PHV\n\nNJ 022751991\n\nSuite 141 Route 130 S.  303\n\nCinnaminson, NJ 08077\n\nBrad@FormerFedsGroup.Com\n\n(856) 607-5708\n\n---\n\n6\n\nCERTIFICATE OF SERVICE\n\nI hereby certify that on April 6, 2026, a true and accurate copy of the forgoing was\nelectronically filed and served through the ECF system of the U.S. District Court for the\nSouthern District of New York.\n\n/s/ Brad Geyer\n\nBradford L. Geyer, PHV\n\nNJ 022751991\n\nSuite 141 Route 130 S.  303\n\nCinnaminson, NJ 08077\n\nBrad@FormerFedsGroup.Com\n\n(856) 607-5708","body_zh":null,"key_entities":[],"ecf_references":[],"word_count":1151,"status":"published","published_at":"2026-04-06 00:00:00","created_at":"2026-04-06","updated_at":"2026-07-06 20:57:18"}