郭文贵上诉 · MOTION · ECF #32
元数据
- 当事人
- 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
- 法院
- 2Cir
- 案号
- 26-1296
- ECF #
- 32
- 类型
- MOTION
- 立案日
- 2026-05-22
紧急动议 —— 美国诉 Ho Wan Kwok(郭文贵 / Guo Wengui / Miles Guo)案,2Cir 26-1296 ECF #32(2026-05-22立案)。善意第三方财产所有人 Bao Chu 自行提请动议,请求全面剔除检方的量刑备忘录(Dkt. 833),强制召开《联邦刑事诉讼规则》第32(i)(2)条及证据规则第104条规定的 Fatico 证据听证会,并签发第17(c)条传票。动议主张检方备忘录存在时间线不实、将独立第三方企业行为不当归咎于被告以及违规提取投资者识别码等问题。
原始法庭文件为英文,下方为英文全文。
全文
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 1 of 64
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 2 of 64 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, Plaintiff, Case No. 1:23-cr-00118-AT -v- HO WAN KWOK, et al., Defendants. EMERGENCY MOTION TO STRIKE SENTENCING MEMORANDUM (DKT. 833) IN ITS ENTIRETY, COMPEL A FED. R. CRIM. P. 32(i)(2) AND RULE 104 EVIDENTIARY (FATICO) HEARING, AND ISSUE RULE 17(c) SUBPOENAS I.STATUTORYMANDATEANDSUPREMECOURTPRECE- DENT Pursuant to Federal Rule of Criminal Procedure 32(i)(2), the Court is under a strict statutory mandate to rule on any disputed portion of the presentence report or other controverted matter. Applicant hereby introduces seven (7) certified, objective exhibits establishing that the Government’s Sentencing Memorandum (Dkt. 833) is predicated upon the knowinguseoffabricatedevidenceandphysicalimpossibilities,directlytriggering the constitutional prohibition established in Napue v. Illinois, 360 U.S. 264 (1959). The Court must convene a Fatico evidentiary hearing; failure to do so upon the 1
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 3 of 64 presentation of unassailable physical records constitutes a structural Due Process violation. II. ABSOLUTE PHYSICAL IMPOSSIBILITY OF THE GOV- ERNMENT’S TIMELINE (NAPUE VIOLATION) In Dkt. 833 (p. 68), the Prosecution alleges the Defendant “continued to di- rect” extrajudicial operations via telephone from the Metropolitan Detention Cen- ter (MDC) at 16:48 EST on March 15, 2023. This assertion is objectively annihilated by the Government’s own records: 1. Court Transcript (Exhibit 1): Official Docket 14 objectively establishes that at exactly 16:55 EST on March 15, 2023, the Defendant was physically present beforeU.S.MagistrateJudgeKatharineH.Parker. Itisphysicallyimpossibleto executeadirectivephonecallfromtheMDCwhileconcurrentlyappearingin a federal courtroom. 2. OfficialBOPTRUVIEWLogs(Exhibit2): Officialprisonlogs(Dkt. 312-3,Bates No. USAO_00297003) conclusively prove the Defendant possessed zero autho- rized telephone contacts prior to March 28, 2023. The Prosecution’s inten- tional submission of a narrative that materially conflicts with its own Bureau ofPrisonsphysicallogsconstitutesprosecutorialmisconductandFraudonthe Court. III.FRAUDULENTATTRIBUTIONOFINDEPENDENTCOR- PORATE CONDUCT TheProsecutionassertsinDkt. 833thattheDefendantcreatedthe“TDCCP”dig- italcurrencytofundlegaldefense. Thisreliesentirelyonextrajudicialproxiesand AI-forged audio (Exhibit 7). 1. NY DOS Corporate Registration (Exhibit 3): Objective public records (DOS ID: 7518505) prove that “ACTION ACTION ACTION LLC,” the issuing entity of 2
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 4 of 64 TDCCP, was unilaterally registered and operated by Government witness For- rest Zhou (Yoe Zhou) on January 27, 2025. 2. Ontario Superior Court Order (Exhibit 4): Case No. CV-25-00753415-0000 (dated May 22, 2026) objectively records that this same entity independently initiated civil litigation and was ordered to pay $53,000 CAD in adverse costs. Attributingtheindependent,legallydocumentedactionsofaGovernmentwit- ness’s registered corporation to the incarcerated Defendant violates the Sixth Amendment Confrontation Clause. IV.PERJURYCONTRADICTEDBYEDITABLEDOCUMENT TRANSMISSION TheProsecutionreliesonthetestimonyofYaLi,claimingshewassubjectedtoa “threatof$38millioninliability”constituting“violentcoercion”byYongbingZhang to sign an affidavit (Dkt. 833, pp. 27-28). The Editable Document Paradox (Exhibit 5): An extrajudicial public admis- sion by Yongbing Zhang on April 10, 2026, objectively establishes that he transmit- ted both a PDF and a fully editable Word document to Ya Li, explicitly instructing her to modify the contents if she disagreed. The physical provision of an editable draft is mutually exclusive with the legal definition of “coercion.” V. MASS IDENTITY THEFT AND THE DOCTRINE OF PER- VASIVE TAINT TheProsecutionseeksextremesentencingenhancementsbyalleging“thousands of victims,” while the docket contains only approximately 225 physical statements. PhishingandHIDTheft(Exhibit6): Objectivelogsprovetheproxyentityestab- lished a phishing website (bragey5.dreamhosters.com) to unlawfully extract Court- 3
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 5 of 64 assignedHIDCodesfrom6,512investors. TheProsecution’ssubsequentuseofthese stolenidentifierstoadministrativelyinflatethevictimrosterunder21U.S.C.§853(i) Remission,overridingtheinvestors’explicitdisclaimersofvictimhood,violatesthe Crime Victims’ Rights Act (CVRA) and triggers the Doctrine of Pervasive Taint. VI. RELIEF REQUESTED Pursuanttotheobjectiveevidentiarymatrixprovidedherein,Applicantdemands the Court: 1. ImmediatelyissueRule17(c)subpoenastotheBOPforcompleteMDCtelecom- munication and visitation logs. 2. CompelaFed. R.Crim. P.32(i)(2)andRule104FaticoHearingtoadversarially test the physical impossibilities present in Dkt. 833. 3. Strike Dkt. 833 in its entirety due to objective, documented Napue violations. Respectfully submitted, /s/ Bao Chu Bao Chu Proceeding Pro Se / Bona Fide Third-Party Property Owner S.D.N.Y. HID: F56BDDZ Dated: June 15, 2026 4
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 6 of 64
N3F5kwoA 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 2 ------------------------------x 3 UNITED STATES OF AMERICA, New York, N.Y. 4 v. 23 Cr. 118 (AT)(KHP) 5 HO WAN KWOK, 6 Defendant. 7 ------------------------------x 8 March 15, 2023 4:55 p.m. 9 10 Before: 11 HON. KATHARINE H. PARKER, 12 U.S. Magistrate Judge 13 14 APPEARANCES 15 DAMIAN WILLIAMS United States Attorney for the 16 Southern District of New York BY: RYAN B. FINKEL 17 JULIANA MURRAY MICAH FERGENSON 18 Assistant United States Attorneys 19 FEDERAL DEFENDERS OF NEW YORK Attorneys for Defendant 20 BY: TAMARA L. GIWA 21 ALSO PRESENT: LILY LAU, Mandarin Interpreter 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
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N3F5kwoA 1 (Case called) 2 THE DEPUTY CLERK: Beginning with the government, 3 please make your appearance for the record. 4 MR. FINKEL: Good afternoon, your Honor. Ryan Finkel, 5 Juliana Murray, Micah Fergenson for the United States. We are 6 joined at counsel table by Geoffrey Mearns, who is a paralegal 7 in our office. 8 THE DEPUTY CLERK: Counsel for Mr. Kwok, please make 9 your appearance for the record. 10 MS. GIWA: Federal Defenders of New York by Tamara 11 Giwa appearing today for Mr. Miles Guo. Good afternoon, your 12 Honor. 13 THE COURT: Good afternoon. And good afternoon 14 Mr. Kwok. 15 THE DEFENDANT: (In English) Your Honor, good 16 afternoon. 17 THE COURT: I'm Judge Parker. 18 Before we get started, Mr. Kwok, I want to make sure 19 that you can understand and hear the interpreter. 20 THE DEFENDANT: (In English) Yes, your Honor. 21 THE COURT: The purpose of today's proceeding is to 22 inform you of certain rights that you have, to inform you of 23 the charges against you, to consider whether counsel should be 24 appointed for you, and decide under what conditions, if any, 25 you shall be released pending trial. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
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EXHIBIT C
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Date: 04/04/2024 Location: DC Federal Bureau of Prisons Time: 09:04 AM TRUVIEW Inmate Center Report Sensitive But Unclassified Contact Contact Creation Date Last Change Date Loc Status Phone First Nm Last Nm AlertedBlock Description 3/31/2023 2:52:19 PM 3/13/2024 2:22:24 PM BRO Active Samu Samu No 3/13/2024 2:22:24 PM 3/13/2024 2:22:24 PM BRO Active Kaili Kaili No 3/13/2024 2:07:21 PM 3/13/2024 2:07:21 PM BRO Active Pallan Pallan No 9/14/2023 5:52:19 PM 9/14/2023 5:52:19 PM BRO Active Dan Dan New Lawyer No 9/14/2023 5:52:19 PM 9/14/2023 5:52:19 PM BRO Active Dan Dan New Lawyer No 8/29/2023 6:07:21 PM 8/29/2023 6:07:21 PM BRO Active May Goo No 8/9/2023 5:52:16 PM 8/9/2023 5:52:16 PM BRO Active Mn Mn No 5/3/2023 1:37:17 PM 5/3/2023 1:37:17 PM BRO Active May Q No 8/9/2023 5:52:16 PM 3/13/2024 1:52:23 PM BRO Inactive On On No 8/4/2023 3:22:21 PM 3/13/2024 1:52:23 PM BRO Inactive New Number New Umber No 8/4/2023 3:22:21 PM 3/13/2024 1:52:23 PM BRO Inactive New Number New Umber No 3/31/2023 8:07:15 AM 3/13/2024 1:52:23 PM BRO Inactive Cangtian Op No 2/1/2024 8:52:16 AM 3/13/2024 1:52:23 PM BRO Inactive Vicky V No 4/1/2023 1:52:16 PM 3/13/2024 1:52:23 PM BRO Inactive Wy Wy No 3/31/2023 2:52:19 PM 3/13/2024 1:52:23 PM BRO Inactive Ml Ml No 8/9/2023 6:22:17 PM 3/13/2024 1:52:23 PM BRO Inactive Mn Mn No 3/28/2023 1:37:19 PM 3/13/2024 1:52:23 PM BRO Inactive New Number New Number No 8/16/2023 7:52:18 PM 3/13/2024 1:52:23 PM BRO Inactive New New New New No 12/10/2023 12:37:23 PM3/13/2024 1:52:23 PM BRO Inactive Jet Li No 8/4/2023 1:22:19 PM 3/13/2024 1:52:23 PM BRO Inactive Kk Kk No 8/8/2023 9:07:20 PM 3/13/2024 1:52:23 PM BRO Inactive New Jersey Jersey No 3/31/2023 2:52:19 PM 3/13/2024 1:52:23 PM BRO Inactive Wen Guo No 8/11/2023 12:22:22 PM 3/13/2024 1:52:23 PM BRO Inactive E E No 8/9/2023 5:52:16 PM 3/13/2024 1:52:23 PM BRO Inactive Cathy Cathy No 8/11/2023 12:07:22 PM 3/13/2024 1:52:23 PM BRO Inactive Cathy Cathy No 8/11/2023 12:22:22 PM 3/13/2024 1:52:23 PM BRO Inactive C C No UUsseerr IIDD:: TF57175 Page 3 of6 USAO_00297003 CONFIDENTIAL
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Date: 04/04/2024 Location: DC Federal Bureau of Prisons Time: 09:04 AM TRUVIEW Inmate Center Report Sensitive But Unclassified Contact Contact Creation Date Last Change Date Loc Status Phone First Nm Last Nm AlertedBlock Description 8/21/2023 7:07:23 PM 3/13/2024 1:52:23 PM BRO Inactive C C No 3/31/2023 2:52:19 PM 3/13/2024 1:52:23 PM BRO Inactive Ab Ab No 3/20/2023 8:52:14 AM 8/29/2023 6:07:21 PM BRO Inactive May Goo No 8/9/2023 5:52:16 PM 8/9/2023 6:22:17 PM BRO Inactive Mn Mn No 6/13/2023 9:22:18 PM 6/14/2023 6:22:25 PM BRO Inactive Qing Zhi No 3/21/2023 7:22:14 AM 5/21/2023 9:22:15 AM BRO Inactive Bing Zhang No 3/16/2023 6:52:19 PM 5/21/2023 9:22:15 AM BRO Inactive No 3/16/2023 6:52:19 PM 5/21/2023 9:22:15 AM BRO Inactive No 4/1/2023 1:52:16 PM 5/21/2023 9:22:15 AM BRO Inactive Ru Shui No 3/21/2023 7:22:14 AM 5/21/2023 9:22:15 AM BRO Inactive Si Qi No 3/28/2023 1:37:19 PM 5/21/2023 9:22:15 AM BRO Inactive An P No 4/22/2023 8:07:18 PM 5/21/2023 9:22:15 AM BRO Inactive S Best No 4/22/2023 8:07:18 PM 5/21/2023 9:22:15 AM BRO Inactive S Best No Calls Contact Contact Start Date Loc Completed Duration Phone First Nm Last Nm City St Country 4/4/2024 8:32:53 AM BRO Yes 15 X X 4/4/2024 7:03:14 AM BRO Yes 15 Gw W 4/3/2024 2:42:12 PM BRO Yes 8 Gw W 4/2/2024 1:22:26 PM BRO Yes 13 Gw W 4/2/2024 12:04:25 PM BRO Yes 15 Gw W 4/1/2024 2:29:57 PM BRO Yes 15 Gw W 3/20/2024 6:52:40 PM BRO Yes 15 Gw W 3/20/2024 5:12:44 PM BRO Yes 1 Gw W 3/20/2024 1:20:58 PM BRO Yes 3 Gw W 3/19/2024 6:48:48 PM BRO Yes 4 Gw W UUsseerr IIDD:: TF57175 Page 4 of6 USAO_00297004 CONFIDENTIAL
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meet in the MDC following his arrest and detention—asked Ya Li to sign a false affidavit for filing in one of the bankruptcy litigations. (Tr. 1523-29; GX VI 66). When she refused, Zhang threatened Ms. Li with $38 million in liability. (Tr. 1530). After this threat from Guo’s attorney, Ms. Li contemplated suicide. (Tr. 1530-31). More recently, Guo’s enterprise continues to harass and threaten those that oppose it. On March 10, 2026, in a video provided to the Government by a victim, Guo’s NFSC presenters requested that Guo’s remaining followers provide statements to Guo’s court appointed counsel. In addition, the presenter indicated that the 126 victims who previously provided statements “will all have to bear the consequences.” (Dkt. 832, Stmt. 206-B (translated)). That appears to be a reference to the 126 victim statements filed with the Court on November 22, 2024. (Dkt. 477). 3. Guo’s Post-Arrest Obstruction Even after his arrest Guo has engaged in obstructive conduct. Guo’s criminal Enterprise continued to operate following his arrest and Guo continued to direct it as it relocated to the UAE, outside the reach of U.S. law enforcement. (PSR ¶¶ 103-105). Following his arrest, Guo’s 27
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 16 of 64 OPENGOVNY Health Authority Business Education Other New York State Health Facilities Overview This dataset includes about 6,000 health facilities registered with the Health Facilities Information System of New York State Department of Health. The Health Facilities Information System (HFIS) contains Article 28, Article 36, Article 40, and Article 7 health care facilities and programs. Each facility is registered with facility ID, facility name, business address, operator name, operator address, telephone, website, open date, etc. Search Facilities Dataset Information Subject Health Jurisdiction State of New York Data Provider New York State Department of Health, Center for Health Care Facility Planning, Licensure, and Finance Source data.ny.gov Dataset Details The Center for Health Care Facility Planning, Licensure, and Finance of New York State Department of Health maintains the Health Facilities Information System (HFIS), which contains the operating certificate information of the following licensed health care facilities: (1) Article 28: Hospitals, Nursing Homes, Diagnostic and Treatment Centers, Midwifery Birth Centers; (2) Article 36: Certified Home Health Agencies, Licensed Home Care Services Agencies, Long Term Home Health Care Programs; and (3) Article 40: Hospices. The information contains the operator and the site of service, including operator name, site address, and certified beds and/or services. This dataset contains the locations of Article 28, Article 36, Article 40, and Article 7 health care facilities and programs from the Health Facilities Information System (HFIS). Article 28 facilities are hospitals, nursing homes, diagnostic treatment centers and midwifery birth centers. Article 36 facilities are certified home health care agencies, licensed home care services agencies, and long term home health care programs. Article 40 facilities are hospices. Article 7 are licensed adult care facilities. Each facility is registered with facility ID, facility name, business address, operator name, operator address, telephone, website, open date, etc. To give New Yorkers the access they deserve to government data and information, Governor Andrew M. Cuomo launched the Open NY initiative in March 2013 and signed Executive Order 95. It directs state agencies to identify, catalog, and publish their data on the state's open data website administered by the Office of Information Technology Services (ITS). Open NY increases transparency, improves government performance empowers New Yorkers to participate in government, and encourages research and economic opportunities statewide. Search Result Facility Name Address Description Open Date Ingersoll Place Licensed Home Care Services Agency 3359 Consaul Road, Schenectady, New York Licensed Home Care Services 2023- Ingersoll Adult Home, Inc. 12304 Agency 06-09 Coopers Corner, Inc. 11 Mill Road. New Rochelle, New York 10804 Adult Home 2023- 06-09 New Vision Home Care Services, Lic 96-09 Springfield Blvd, Unit 204, Queens Licensed Home Care Services 2023 Village, New York 11429 Agency 05-25 Anchor Health Homecare Services Inc 173 Huguenot Street, Suite 221, New Licensed Home Care Services 2023- Rochelle, New York 10801 Agency 05-24 Sunrise Home Care, Inc 15 Cooledge Drive, Brewster, New York 10509 Licensed Home Care Services 2023- Agency 05-22 St. Peter's Hospital -SPARC St Peters Hospital Inc 1300 Massachusetts Avenue, Troy, New York Hospital 2023 12180 05-15 Westside Health Center Housing Works Health 326 West 48th Street, New York, New York Diagnostic and Treatment Center 2023- - Services III, Inc. 10036 Extension Clinic 05-12 Daniel Squire Oral D & T Center Mobile School-Based Squire Hall-3435 Main Street- SUNY/B, 3425 School Based Diagnostic and 2023 Dental Unit Main St, Buffalo, New York 14214 Treatment Center Extension Clinic 05-04 Field of Dreams Senior Living Olean Manor, Inc 3260 N 7th Street, Cattaraugus, New York Licensed Home Care Services 2023- 14706 Agency 04-25 Ultimate Care INC Ultimate Care, Inc 250 Fulton Avenue, Suite 511, Hempstead Licensed Home Care Services 2023- New York 11550 Agency 04-06 Ultimate Care Inc Ultimate Care, Inc. 280 Route 211 East, Suite 202, Middletown, Licensed Home Care Services 2023 New York 10940 Agency 04-06 Sun River Health White Plains Sun River Health 360 Mamaroneck Avenue,W hite Plains, New Diagnostic and Treatment Center 2023- Care, Inc. York 10605 Extension Clinic 03-29 Sun River Health Copiague Sun River Health Care, 445 Oak Street, Copiague, New York 11726 Diagnostic and Treatment Center 2023
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 17 of 64 opengovny.com/corporation/7518505#google_vignette
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 18 of 64 OPENGOVNY Health Authority Business Education Other New York State Corporation Entity Overview Action Action Action LLC Location Information Similar Entities 87-10 51 Ave., Rm 2P, Elmhurst, NY 11373 Dataset Information Overview ACTION ACTION ACTION LLC (DOS #7518505) is a Domestic Limited Liability Company in Elmhurst registered with the New York State Department of State (NYSDOS). The business entity was initially filed on January 27, 2025. The registered business location is at 87-10 51 Ave., Rm 2P, Elmhurst, NY 11373. The DOS process contact is Action Action Action LLC. Business Entity Information DOS ID 7518505 Current Entity Name ACTION ACTION ACTION LLC County Queens Jurisdiction New York Entity Type DOMESTIC LIMITED LIABILITY COMPANY Initial DOS Filing Date 2025-01-27 DOS Process Name ACTION ACTION ACTION LLC DOS Process Address 87-10 51 Ave., Rm 2P Elmhurst NY 11373 Lastest Filing Information Filing Number 250127002666 Filing Type ARTICLES OF ORGANIZATION Mod Cert Code 01DAA Approved Date 2025-01-27 Filing Date 2025-01-27 Entity Type DOMESTIC LIMITED LIABILITY COMPANY Current Entity Name ACTION ACTION ACTION LLC Effective Date 2025-01-27 Duration PERPETUAL Law Section LIMITED LIABILITY COMPANY LAW 203 LIMITED LIABILITY COMPANY LAW - County Queens Jurisdiction NY Filer Name FORREST ZHOU Filer Address C/O Cmly & Associates LLC 3636 Prince St. #307 Flushing NY 11354 DOS Process Name The LLC DOS Process Address 87-10 51 Ave.. Rm 2P Elmhurst NY 11373 Entity Name History Filing Date Entity Name Filing Number Type Status 2025-01-27 ACTION ACTION ACTION LLC 250127002666 Actual Active Entity Address History
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 19 of 64 Overview Mod Cert Code 01DAA Location Information Approved Date 2025-01-27 Similar Entities Filing Date 2025-01-27 Dataset Information Entity Type DOMESTIC LIMITED LIABILITY COMPANY Current Entity Name ACTION ACTION ACTION LLC Effective Date 2025-01-27 Duration PERPETUAL Law Section LIMITED LIABILITY COMPANY LAW 203 LIMITED LIABILITY COMPANY LAW - County Queens Jurisdiction NY Filer Name FORREST ZHOU Filer Address C/O Cmly & Associates LLC 3636 Prince St. #307 Flushing NY 11354 DOS Process Name The LLC DOS Process Address 87-10 51 Ave., Rm 2P Elmhurst NY 11373 Entity Name History Filing Date Entity Name Filing Number Type Status 2025-01-27 ACTION ACTION ACTION LLC 250127002666 Actual Active Entity Address History Filing Date Address Type Address Name Address Filing Number 2025-01-27 Service of Process The LLC 87-10 51 Ave., Rm 2P. Elmhurst. NY 11373 250127002666 Location Information Street Address 87-10 51 Ave.. Rm 2P 在 Google 地图中打开 纽约 to新 wn城 Hi高 gh中 School 50th Ave StC ai tt ey NEl Ymhurst Dongan tJames 51 Zip Code 11373 met Corona Ave. 8 57 t 1t hh s S tt A 50th Ave Apt 2p 51st Ave 51st Ave oadw 52nd Av 5e 3rd Av So 键o 盘g 快le 捷 说A ve 地图数据 ©2026 Google GS(2011)6020 条款 Corporations in the same zip code Corporation Name Address Registered Agent Name Initial DOS Filing Date Yongwu Inc. 88-23 54 Avenue, Elmnurst, NY 11373 2026-05-26 Arcentales LLC 4319 Judge St Fl 1, Elmhurst, NY 11373 2026-05-19 Obsidian Gaa Inc. 89-20 55th Ave., 5q, Elmhurst, NY 11373 2026-05-29 Topg Remodeling Corр. 91-01 lamont avenue, Elmhurst, NY 11373 2026-05-19 Myagdiko Family Grocery Store Inc 9311 50th Ave, Elmhurst, NY 11373 2026-05-18 Bormate Thera Kines Rehab LLC 9048 53rd Ave, Elmhurst, NY 11373 2026-05-22 Gentle Guardian Homecare Inc. 5135 Simonson St, 1st Flr, Elmhurst, NY 11373 2026-05-26 Entree Foods Inc. 5109 Gorsline St, Elmhurst, NY 11373 2026-05-22 Omni Cable LLC 83-69 Vietor Ave #3, Elmhurst, NY 11373 2026-05-27 Almas It Service Corp 94-27 Corona Ave, Queens, NY 11373 Luis Santiago Sanchez Batista 2026-05-29 Find all corporations in the same zip code Similar Entities Corporations with similar names
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 20 of 64 Overview Corporations with similar names Location Information Corporation Name Address Registered Agent Name Initial DOS Filing Date Love In Action Doula Services LLC 26 BellA ir Lane, Wappingers Falls1, NY 12590 2024-03-04 Similar Entities Action Financial Planning, Inc. 191 north avenue, Mount Clemens, MI 48043 2024-04-22 Dataset Information A Call for Action To Vote, Inc 3005 village park drive, Spring Hope, NC 27882 2022-12-12 Improve Information Do you have more infomration about Action Action Action LLC? Please fill in the following form. Name Address Telephone Email Website Content Submit Form Dataset Information This dataset includes about three million business entities and corporations registered with New York State Department of State (NYSDOS). The Department of State keeps a record of every filing for every incorporated business in the state of New York. Each business entity is registered with DOS ID, business legal name, type, filing date, registered agent name, office address, etc. Subject Business and Economy Jurisdiction State of New York Data Provider New York State Department of State (NYSDOS) Source data.ny.gov Search Corporations Dataset Details The New York State Department of State, one of the oldest and most diverse agencies in state government, works to make New York a more welcoming, equitable, and prosperous place for all who call it home. Established in 1778, and known as the Keeper of Records for more than two centuries, the Department improves the quality of life for all New Yorkers by providing a myriad of essential services and programs to local governments, businesses, community organizations and citizens. Business corporations, not-for-profit corporations, limited liability companies and limited partnerships must file a formation document with the New York State Department of State in order to do business within the State of New York Each corporate, limited liability company or limited partnership name must be unique. Out-of-state corporations which choose to do business in New York State must file with the Department of State an application for authority. If the entity name is not distinguishable from the name of all other entities on file with the Department of State, the corporation must use a fictitious name which, likewise, must be distinguishable from the name of allo ther entities on file with the Department of State. With some exceptions, each business corporation must submit a statement every two years verifying their service of process address and identifying the name and address of the chief executive officer of the corporation and the address of the principal executive office of the corporation. Limited liability companies must submit a statement every two years that verifies the service of process address. This Corporation and Business Entity Database includes business and not for profit corporations, limited partnerships, limited liability companies, limited liability partnerships, and other miscellaneous businesses. The database also includes assumed name filings for corporations, limited liability companies and limited partnerships. Each business entity is registered with DOS ID, business legal name, entity type, filing date, registered agent name and address, officer name and address, office address, etc. To give New Yorkers the access they deserve to government data and information, Governor Andrew M. Cuomo launched the Open NY initiative in March 2013 and signed Executive Order 95. It directs state agencies to identify, catalog, and publish their data on the state's open data website administered by the Office of Information Technology Services (ITS). Open NY increases transparency, improves government performance, empowers New Yorkers to participate in government, and encourages research and economic opportunities statewide. OPENGOVNY Contact
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Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 22 of 64 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, Case No. [CASE NUMBER] -v- [DEFENDANT NAME], EXHIBIT AA Defendant. EXHIBIT AA: PROFFER OF NEWLY DISCOVERED EVIDENCE AND COMPLETE TRANSCRIPTS (Extra-Judicial Admissions by Witness Yongbing Zhang on the GETTR Platform and Public Broadcasts) DECLARATIONOFGOOD-FAITHTRANSLATIONANDBURDENSHIFTINGDue 1 to extreme exigent circumstances and the immediate proximity of the sentenc- 2 inghearing,I,appearingProSeasaprotectedthird-partyrights-holder,lackthe 3 time and financial resources to obtain a formally certified translation of these 4 newly discovered, highly exculpatory public posts and broadcasts. The English 5 texts provided below constitute a complete, unredacted, good-faith, and accu- 6 ratereferencetranslationoftheoriginalChinesematerialsauthoredandspoken 7 by Yongbing Zhang (a.k.a. “Changong Qixia” / “Fatong”). 8 ShouldtheGovernment—whichpossessesinfiniteinvestigativeresources, 9 employsin-houselinguists,andactivelymonitorsthesespecificcooperators’so- 10 cial media accounts—dispute the accuracy of these complete translations, the 11 1
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 23 of 64 burden shifts entirely to the Government to produce an official, certified trans- 12 lation for the Court. The Government must not be permitted to exploit a Pro Se 13 rights-holder’s lack of immediate access to certified translators as a procedural 14 loophole to suppress incontrovertible evidence of its own Napue violations and 15 Fraud on the Court. 16 ——————————————————————————– 17 DOCUMENT 1: FULL TRANSLATION OF GETTR POST BY YONGBING ZHANG 18 (DATED JANUARY 18, 2026) (Reference: Original Screenshots 1-4) 19 ”AtnoononSaturday,January17,EST,Qixia[YongbingZhang]visited[the 20 Defendant] in the capacity of a lawyer. The sky in New York was covered with 21 dark clouds that day, and snowflakes and drizzle fell from the sky from time to 22 time. Due to the arrival of the Maduro couple, the layout of the outer perime- 23 ter of MDC has changed a lot compared to when I visited in September 2025. 24 Iron protective fences have been set up at all surrounding intersections. But 25 one thing has not only not changed, but has actually increased, and that is the 26 artdisplaysupporting[theDefendant]constructedbyfellowfightersonthepro- 27 tectivenetaroundMDC. Since[theDefendant] enteredMDCon March15, 2023, 28 such displays have never been interrupted. In the past, it was on the side of the 29 WestBuildingfacingtheStatueofLiberty,because[theDefendant]waslivingin 30 theWestBuildingatthattime. Uptonow,as[theDefendant]hasbeenmovedto 31 the East Building, the display on the west side is still visible, and right at the en- 32 trancefacingtheEastBuilding,fellowfightershaverecentlyconstructedavery 33 eye-catching banner, nearly ten meters long and about three meters high. It is 34 made of bunches of colorful small flowers tied to the mesh wall, featuring a G 35 logo and a line of text: ’Winter Month Thirteen LOVE GUO’. When I visited last 36 September, this banner was not there. 37 2
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 24 of 64 After entering the building, I quickly completed the registration proce- 38 dures, passed through security, and entered the visiting area. I chose the same 39 room where I had a meeting with [the Defendant] last time. It is about 1.5 me- 40 ters wide and over 2 meters long. The room contains a small table and four 41 chairs. There is a computer and a monitor on the table. This is one of only two 42 meeting rooms equipped with computers, and the computer in the other room 43 isobviouslynotpluggedin. Iquicklysetupmydocumentsandotheritems,then 44 boughtsomesnacksanddrinksfromthevendingmachine. Fullyprepared,Isat 45 down in the room, waiting for [the Defendant]. 46 Before long, [the Defendant] appeared at the duty desk, chatting with the 47 female guard who brought him over while looking towards the meeting room. 48 Upon seeing me, he laughed. I also stepped out of the room to greet [the Defen- 49 dant]. [The Defendant] held a thick stack of documents and a document bag in 50 his left arm and opened his right arm. I also opened my arms, and [the Defen- 51 dant] and I hugged tightly. Time seemed to stop at that moment. I put down my 52 arms, looked closely at [the Defendant], and then hugged him again. I silently 53 recited in my heart that this hug was given on behalf of the fellow fighters. We 54 walkedintotheroom,and[theDefendant]saidwithasmilewhileputtingdown 55 the documents: ’This room has become exclusively mine.’ After we sat down, 56 [the Defendant] said again: ’Haha, it really feels like a dream.’ 57 We read the documents while discussing. [The Defendant] always talks 58 endlesslyabouthisviewsonthecase,currentaffairs,history,theWhistleblower 59 Movement, and so on. [The Defendant] has been in MDC for nearly three years. 60 Althoughlivinginsuchanincrediblyharshenvironment,theglobalCCP-takedown 61 movementcreatedby[theDefendant]hasneverpausedforamoment. MDChas 62 merelybecomeanotherlocationfor[theDefendant]tocontinuetakingdownthe 63 CCP.[TheDefendant]toldmethateverydayinMDC,hefirmlyrememberstodo 64 3
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 25 of 64 threethings: First: prayingtothemillionsofBuddhasandgodsfortheWhistle- 65 blower Movement and fellow fighters cannot be reduced one bit; Second: his 66 own personal safety and health are not his personal matters but the matters of 67 the fellow fighters; Third: grasp every minute and second to study and work, 68 wasting no time. 69 When discussing Document No. 789 recently submitted to the court by 70 [theDefendant]’scriminaldefenselawyer,[theDefendant]wasveryexcited. He 71 said: ’It was exactly in this room, several of their lawyers sat on the side where 72 you are sitting now, and I was still sitting in the chair you are in now. We dis- 73 cussed and scrutinized it word by word. This is a big deal! Qixia.’ He said any- 74 thing involving the core interests of fellow fighters is a big deal. I recalled that 75 incourtonMarch15,theprosecutormobilizedalargeforceanddeclaredtothe 76 judge: ’giventhemultitudeofthousandsofvictimsinthiscase’(March15,2023, 77 CourtTranscript,Page3,Lines7-8). However,intherulingonthedisposalofthe 78 assetsinvolvedinthecasereturnedtothecourtlastweek,theexactsameprose- 79 cutorswroteinblackandwhiteinDocumentNo. 785thatasofJanuary9,2026, 80 (only) 134 people submitted applications through the court. The applications 81 mailedtothegovernment,whichistheprosecutor,were(only)238. (’...approxi- 82 mately134purported§853(n)claimswerefiledonthedocket.’ ’Inaddition,the 83 Governmenthasreceivedapproximately238purported§853claimsbymail,...’ 84 See footnote 3 on the last line of Page 3 of Document No. 785). Shouldn’t the 85 prosecutor explain such a massive discrepancy? 86 Regarding those who relied on the Whistleblower Movement to amass 87 ill-gotten wealth, gained unprecedented reputation, and then left the Whistle- 88 blower Movement or were swept out by it, [the Defendant] stared at me tightly 89 and said sternly: ’If these people had not originally participated in the Whistle- 90 blower Movement, how could they possibly have gained this wealth and repu- 91 4
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 26 of 64 tation? NowthattheyhavelefttheWhistleblowerMovement,theyarenothing! 92 Their illegal acts will certainly be legally pursued.’ 93 Every time I meet or even talk on the phone with [the Defendant], I feel 94 as if I am in a huge magnetic field with endless energy pushing me forward. I 95 alsofeelliketimeisonahigh-speedtrain,andthemomentofpartingarrivesin 96 a flash. [The Defendant] stood up and said: ’Let’s go, because there are families 97 gatheringoutsidetheroom,Icannotwalkyoutothedutydesk,wecanonlysay 98 goodbyehere. Waitforthemtotakemeback.’ Ipackedmybelongings. Stoodup. 99 Hugged[the Defendant]tightly again. Once again, I feltthe strength broughtby 100 [the Defendant]’s iron-wall-like body. [The Defendant] said to me again: ’After 101 you go out, if there are fellow fighters still outside, please make sure to pass on 102 mygreetingsandexpressmygratitudetothem. Tellthem,don’tstayoutside,it’s 103 too cold. Speaking of this makes my heart ache.’ 104 Ipushedthedooropen,walkedafewsteps,andlookedbackat[theDefen- 105 dant]. He stood there smiling and waving at me. I turned around and took big 106 strides towards the duty officer who had already opened the first door for me. 107 Afterpassingthroughthetwodoors,Ilookedbackagain,hoping[theDefendant] 108 could walk into my line of sight on his way back. 109 Special thanks to Secretary Qingteng and multiple fellow fighters in New 110 York for the logistical support and preparation provided.” 111 ——————————————————————————– 112 DOCUMENT 2: FULL TRANSLATION OF GETTR POST BY YONGBING ZHANG 113 (DATED JANUARY 28, 2026) (Reference: Original Screenshots 5-6) 114 ”AtnoononJanuary26,EST,QixiacametoMDCtovisit[theDefendant]. A 115 heavy snow had just fallen in New York the day before. The temperature plum- 116 metedtomorethantendegreesbelowzeroCelsius. Thevisitingareaonthefirst 117 5
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 27 of 64 floor of the East Building of MDC was also permeated with cold air. As soon as 118 he saw [the Defendant], he excitedly expressed that I, as a fellow fighter of the 119 Whistleblower Movement, brought him warmth and strength. During this pe- 120 riod of historical major events, [the Defendant] misses his sisters and brothers 121 even more. We immediately talked about Mr. Zhang Youxia. [The Defendant] 122 said General Zhang is already the greatest hero among the Chinese sons and 123 daughters. He is saving humanity and is a true great hero taking down the CCP. 124 Inthefuture,therewillbecountlessZhangYouxiasandLiuZhenlisstandingup. 125 More and more people will deeply believe: ’Taking down the CCP is a necessity 126 for justice,’ the cry issued by Brother Haidong when reading the declaration of 127 the New Federal State of China on June 4, 2020. 128 [TheDefendant]gavehighpraisetotheactionsofSecretaryQingtengand 129 theExecutiveCommittee,aswellasthebrothersandsistersofvariousfarmsthis 130 week. Let everyone continue to act. [The Defendant] hopes that fellow fighters 131 will widely spread the truth to awaken more people domestically and abroad 132 to recognize this historical event. First, five questions must be raised. 1. Did 133 Zhang Youxia do this for money? 2. Did he do this so he could run to the United 134 States? 3. WereZhangYouxiaandLiuZhenlitakendownbecauseofcorruption 135 or male-female relations? 4. What is the core purpose of Zhang Youxia and Liu 136 Zhenli doing this? 5. What is the possible reaction of the United States to Zhang 137 Youxia’s actions? 138 Secondly, fellow fighters should pay attention to the four major impacts 139 producedbythisincident. First: AwakeningtheUnitedStatesandmoreChinese 140 people; Second: The leaked materials by Zhang Youxia cannot possibly be just 141 nuclear weapons data. The impact brought by this; Third: The joint defection 142 of the two highest-ranking professional military generals of China predicts that 143 more generals will stand up; Fourth: The shocking effect on Russia, the BRICS 144 6
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 28 of 64 countries, and other allies of the CCP. 145 Unknowingly, three hours passed. Upon leaving, [the Defendant] and I 146 hugged tightly. I could feel the strength brought to [the Defendant] by the inci- 147 dent of Zhang Youxia and Liu Zhenli taking down the CCP together. Despite the 148 severe cold, I could feel the blazing fire burning on [the Defendant] because of 149 this! 150 Please, fellow fighters, watch, spread and promote the live broadcast of 151 theallianceonJanuary26. Init,Iandfourotherfellowfighters(BrotherHaidong, 152 Mr. Sanpiao,SecretaryQingteng,Ava)detailed,exploredandcommentedonthe 153 above five questions and four impacts. 154 Fellowfighters,staystrong! Loveyouall! ShenxianYangguCountyDagao 155 County!!!” 156 ——————————————————————————– 157 EXHIBIT:FULLTRANSCRIPTOFAPRIL10,2026PUBLICBROADCASTSpeak- 158 ers: An Hong (Host), Yongbing Zhang (a.k.a. “Changong Qixia” / “Fatong”) 159 Subject: Extra-Judicial Admission Regarding the $38 Million HCHKBVI Cor- 160 porate Dispute 161 [BEGIN COMPLETE TRANSLATION] 162 AnHong(Host): ”Helloeveryone,thisisApril11,2026,AustralianEasternTime, 163 andtheafternoonofApril10,2026,USEasternTime. Today,firstofall,Iwantto 164 say to everyone that last week, due to some reasons, we postponed for a week. 165 At that time, we also thought that exactly this week the documents from the 166 government’s side would come out, so I agreed with fellow fighter Changong 167 Qixia[YongbingZhang]todothisepisodetoday. Ialsowanttoaskfellowfighter 168 Qixia today. First, because fellow fighter Changong Qixia is on a business trip 169 today and has official duties, it is inconvenient for him to show his face as he 170 7
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 29 of 64 is on the road. Therefore, we are interviewing fellow fighter Qixia via a phone 171 connection. Next, let’s invite fellow fighter Changong Qixia to say hello to us. 172 Thank you.” 173 Yongbing Zhang (Changong Qixia): ”Thank you, fellow fighter. Thank you, 174 fellow fighter An Hong, and thank you to all the fellow fighters globally. Hello 175 everyone, regardless of whether it is morning or evening for you, or perhaps 176 noon. Hello everyone, today is the weekend here in the US Eastern Time zone; 177 maybe some fellow fighters are already enjoying their weekend. Regardless, I 178 wish everyone a very good weekend. Today, the topic I want to discuss is some- 179 thing everyone is definitely very interested in. So, I will use this audio connec- 180 tion to talk with fellow fighter An Hong about two important court documents. 181 In doing this program with fellow fighter An Hong today, the content I discuss 182 in this program represents only my own personal views. It does not represent 183 any party, it does not represent [the Defendant], nor does it represent [the De- 184 fendant]’slawyers. Itismerelymyownpersonalopinion,anddoesnotserveas 185 any legal reference or advice. Alright.” 186 Yongbing Zhang: ”An Hong, let me first say, today’s topic is called Q&A, right? 187 ItjustsohappensthattodayIcanalsotakethisopportunitytoexplaintoevery- 188 one... to explain to everyone how this whole thing unfolded.” 189 An Hong: ”Regarding the 38 million, 38 million.” 190 Yongbing Zhang: ”Yes, this 38 million. Yes, regarding this... when Li Ya [Mu- 191 lan] testified, she said that Changong Qixia forced her to sign a so-called fake 192 affidavit. And then, she claimed that because he forced her, she ultimately de- 193 veloped suicidal thoughts. OK.” 194 An Hong: ”Mm.” 195 Yongbing Zhang: ”Let me disclose a few things to everyone... because I am the 196 person who personally experienced this, so I need to tell everyone. First, when 197 8
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 30 of 64 I sent the then-fellow fighter Mulan, the document she claimed I forced her to 198 sign... itwasn’tjustadocument. IntheIronBloodGroup,whereallthemembers 199 of the Iron Blood Group were present, I sent her a message, similar to a text 200 message but maybe a bit longer. My point was, ’Hey, the 38 million belonging to 201 thefellowfightersiscurrentlybeingtargetedbyL[TrusteeLucA.Despins]who 202 is attempting to take it away.’ I told her, from a legal perspective, you can do 203 this because the company is currently in legal proceedings. For this company, 204 known as HCHKBVI, a BVI company, besides [Yvette Wang] being a director, the 205 other director was exactly Mulan, OK, which is Li Ya. She was a director at the 206 time, OK.” 207 ”Legallyspeaking,thatmeansinJulyandAugust2023. Mulanwasadirec- 208 torofHCHKBVI.Atthattime,[YvetteWang]wasalreadyintheMDC.Mulanwas 209 inAustralia,OK.Naturally,therearemanydocumentsconcerningtheHCHKBVI 210 company that must be handled by a director. For instance, if you need to hire 211 a lawyer to respond to a lawsuit. Only a director can do that, so I told her, ’You 212 are a director. From a legal perspective, these matters are within the scope of a 213 director’s duties.’” 214 ”There is another very important point. Today I want to give everyone a 215 breakingrevelation,orrather,ifeveryonecarefullychecksthecourtdocuments, 216 actually, back at that time, actually in August 2023, she had already cooperated 217 withtheprosecution... alreadycooperatedwithLuke[theTrustee]. Idon’tknow 218 if she was cooperating with the prosecution then.” 219 An Hong: ”Mm.” 220 YongbingZhang: ”Ifeveryonecheckswhatshesaidduringthehearingsbefore 221 the jury, maybe she was already cooperating with the police at that time. That 222 is to say, when she was doing these things, when we asked her to protect the 223 interests of the fellow fighters, the interests of the 38 [million], she was actually 224 9
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 31 of 64 already secretly shaking hands with at least L [the Trustee]. She was communi- 225 cating with him. Why? Why? Because we have L’s... we have documents show- 226 ing,OK,thereisevidenceshowing,thatatthattimeshewasalreadycooperating 227 with Luke. And when did I send the document to Mulan? It was September 2, 228 2023. Which means, at that time, she was already L’s person. OK.” 229 ”And now I want to give everyone a detail. What is it? When I sent the 230 document to Mulan, when I sent her the email, I sent her two files. One file was 231 a PDF version of the affidavit.” 232 An Hong: ”Mm.” 233 YongbingZhang: ”OnefilewasaWordversionoftheaffidavit,OK.Myintention 234 was to tell her, ’Here are two versions. If you disagree, you can go ahead and 235 modify it, because I gave you the Word version.’” 236 An Hong: ”Right.” 237 Yongbing Zhang: ”Right? So there was absolutely no such thing as... forcing 238 her. How am I forcing her? Everyone, use your normal human brain to think 239 about it. I am in the US, right? There is a 16-hour time difference between us, 240 how could I force her? Right? That is... right. So from this point, I don’t know 241 how all her testimonies were prepared, OK. So today, I am very, very glad to 242 have this opportunity to tell everyone. Ah, so my name is clearly written in 243 blackandwhiteinDocument833once,andthentwicemore... Ah,so,thisisthe 244 second point I am sharing with you all, or answering your second question. I 245 don’tknowifIanswereditcompletely,Igetabitexcitedwhenspeaking,maybe 246 I went a little off-topic.” 247 [END COMPLETE TRANSLATION] 248 Note on Media Exhibit Submission: Due to the Court’s 10MB electronic fil- 249 ing size limit for email submissions, an audio extraction of the 7-minute broad- 250 10
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 32 of 64 cast (Exhibit: Extra-Judicial Admission by Yongbing Zhang) is attached hereto 251 in .mp3 format. The original, full-length video file is preserved and immedi- 252 ately available for submission via physical media (USB drive) upon the Court’s 253 request. 254 11
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 33 of 64
bragey5.dreamhosters.com/提交宣誓书/ Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 34 of 64 HIMALAYA RESTORATION News Update Contact Us FILE AN AFFIDAVIT 提交宣誓书 我们不再接受新客户。法院要求每位现有客户提交一份宣誓书。请填写右 侧表格,立即提交您的宣誓书。 宣誓书(支持附属或赦免请愿) NEW accessed using HID#* Sign HID #* 通过在上面两次输入我的唯一 HID# 作为我的签名,我在此根据伪证罪的处罚声明,我已仔细审查以下信息,并且根据美国法 律,在我所知范围内,它是真实和正确的: 1. 索赔人的身份和资格 A. 我的身份信息由喜马拉雅交易所(HEX) 安全持有,并可使用上面的 HID# 访问。 B. 我根据 21 U.S.C. § 853 (n) 和联邦刑事 诉讼规则第32.2 (C) 条提交本宣誓书,主张我在美国诉 Ho Wan Kwok 别名“Miles Guo"案(案号 23-cr-118 (AT) (S.D.N.Y.))中 没收财产的合法权益。C. 财产的合法所有者,该财产作为稳定币储备由喜马拉雅交易所持有。我对任何非法活动 无所知,也没有参与其中,我作为无辜投资者以善意获取了我的资产。 D. 我授权 Former FedsG roup.Com LLC 继续代表我行 事,积极追究此索赔,并寻求恢复我的HDO 余额的等值金额,以及与我的HCN 资产贬值相关的任何相关损失,如下所述。根据 银行记录和 的账 2021年4月开放后以及美国政府于2022年9月扣押前进行了这些购 2. 没收财产的描述 A. 没收财产的详细信息存储在HEX 的账户记录中, 喜马拉雅美元 稳定币余额和相关的喜马拉雅币(HCN) 余 额。HDO 稳定币储备作为政府在上述案件中没收行动的一部分被扣押或冻结,金额达数百万美元,来自喜马拉雅交易所的银行账 户。B. 我的HDO 余额代表一种稳定的币投资,旨在作为安全的、与美元挂钩的资产,而我的HCN 持有与平台的交易生态系统 相关联。该扣押导致这些资产严重贬值并无法访问。C. 政府扣押 HEX 平台和网站使我无法访问我的账户信息,但 HEX 已认证我 为客户,并提供了 HDO、HCN、存款和赎回的账户价值,我授权我的律师提供这些信息 索赔依据 A. 我的索赔基于以下财产的合法权益:我是该财产的合法所有者,即从扣押的稳定币储备中相当于我的 HDO 余额的美元金 额,我的权利先于政府的没收程序。,我的权益优于任何政府索赔,因为我在相关犯罪发生前或以善意且不知任何可没收行为的 情况下获取了该财产。该财产是合法获取的,如 HEX 记录中详尽描述,包括交易历史、存款和账户报表,显示我未参与任何所 谓的欺诈计划。 所有建立我所有权权益的文件和账户历史均存储在HEX 的记录中,我授权在安全条件下发布。B.作为21 U 它USS 是.C C 一 . 个9S 88 合55 33 法(( n 的0 )) 加(( 66 密)) 下 货下的 币的干 交无 易 辜所 所所有 ,有者 提者, 供,我 我 H对 对 D该 O该 财 财 (产 产 稳与 与 定非 币)和HCN(一 交无 易所 代知 币, )也 以沒 实有 现合 无理 国的 界理 金出 融相 自信 由这 ,一 如点 公。 开我 宣 传页 所 述ME 。X C, .相相 与位 HDO 资产相关的具体损失:政府的扣押导致交易所停止赎回,因为它不再拥有储备资金。在没收前,客户能够提出赎回请求并将 HH CD NO 兑 资换 产为 相美 关元 的。 具我 体寻 损求 失从 :喜 政马 府拉 的雅 扣押交 以易 及所 随的 后扣 押 H美 C元 N储 (备 喜资 马金 拉中 雅恢 币)复 的我 贬的 值 H 造D 成O 了余 直额 接的 的等 财值 务金 损额 害( 。作 在为 没稳 收定 前资 ,产 H) C。 NND . 作作 与 为为 HEX 生态系统的一部分具有价值,但平台的交易停止和资产冻结导致价值损失。 我寻求政府对我的 HCN 余额损失的补偿损害赔 偿,按喜马拉雅交易所暂停交易时的市场价格计算。 遵守没收程序 A. 我根据 21 U.S.C. § 853(n) (2) 要求的法定截止日期提交此索赔。 B. 我请求法院根据21 U.S.C. § 853(n) (4)-(5) 和 Fed. R. 果果Cr 法法im 院院. P 拒拒. 绝绝32 此此.2 辅辅 (C 助 助) 的 请 请规 质 愿定 , ,安 我 我排 提 提辅 交 交助 以 以听 下 下证 陈 陈会 述 述, 以 以以 支 支审 持 持理 提 提我 交 交的 给 给索 司 司赔 法 法, 部 部呈 的 的交 减 减我 免 免的 请 请无 愿 愿辜 , ,所 根 根有 据 据权 2 证 28 8据 CC .., FF .并 . RR .挑 P P战 aa rr没 tt 9收 9 对 ((我 行行 政的 政 、资 、 民产 民 事的 事 和适 和 刑用 刑 事性 事 没没。 收收C 的的. 减减 如 免或缓解规定)。 我是一名无辜所有者,对没收财产具有合法的财务权益,在不知欺诈的情况下获取。我请求司法部行使其酌情 权,批准没收的减免或缓解,注意到没收程序最初并非设计用于处理像 HEX 这样的海外加密交易所,导致对无 用户造成不成比 例的损害。我请求返回 HEX 持有的所有资金,包括我的 HDO 余额的等值金额,而不使用索赔管理员以节省成本和提高效率。 我未被喜马拉雅交易所欺诈。唯一造成的损失是由于政府扣押和行动,导致交易所停止交易。 5. 请求的救济 A. 我恭敬地请求法院在此辅助请愿下:承认我作为无辜第三方的有效且优越的财产权益。,将我的索赔财产排除在政府的没收 令之外,包括释放相当于我的 HDO 余额的美元。·授予法院认为公正和适当的任何其他救济,例如证据听证会或对 HEX 记录的 发现,以验证我的索赔。 B. 如果法院不批准此辅助请愿,请接受此作为美国司法部减免程序下的返回减免请愿。我请求不使用 索赔管理员以节省成本。我授予根据司法部和 HEX 同意的条款访问权限,并采用最严格的安全程序来保护我的信息,鉴于交易 所的海外性质以及潜在的隐私和其他严重风险。我寻求完全减免,包括我的 6. 授权 A. 我授权 HEX 向法院、政府或指定的第三方提供我的账户信息,以供审查,但须遵守保护条件,以确保我的身份不公开,从而 保 C.护 我我 授的 权安 法全 院。 、 政B. 府我 或授 指权 定 Fo 的r 第me 三rF 方ed返s 回Gr 资ou 金p. ,C 直om 接 L或LC通 代 过表 H我 EX的 协法 调律 的权 第益 三, 方继 返续 回追 。究 我索 理赔 解, 最并 终在 程所有 序相 将关 由程 法序 院中 批代 准表 ,我 我行 请事 求。 它 考虑资产的加密性质(例如,按扣押价值转换为法定等值以减轻损失)。 我根据伪证罪的处罚声明,前述信息在我的知识和信念范围内是真实、正确和完整的。 HID#并选择“提 交”,我确认我的身份,并授权通过我的 HEX 账户记录验证此声明。 Submit
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 35 of 64 2026/3/26 Himalaya Farm Alliance Committee Notice Notice Regarding the Urgent Submission of the Himalaya 🚨 Exchange Affidavit "Please, the 6,512 investors who participated in the Himalaya Exchange class action in 2023 and 2024, submit 🚨 the affidavit via the following link as soon as possible." Those who have forgotten whether they have already submitted it can submit it again, which will not affect the validity of previous submissions. Affidavit Link: http 宣誓书/ Please forward this to all farms and ask investors to inform 🚨 each other. "Himalaya Farm Alliance Executive Committee, March 25, 🚨 2026"
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 36 of 64 We no longer accept new clients. The court requires every existing client to submit an affidavit. Please fill out the form on the right and submit your affidavit immediately. NEW Affidavit (In Support of Ancillary or Remission Petition) **accessed using HID# *** **Sign HID # *** By entering my unique HID# twice above as my signature, I declare under penalty of perjury that I have carefully reviewed the following information, and to the best of my knowledge and belief under U.S. law, it is true and correct: 1. Identity and Qualification of Claimant A. My identity information is securely held by the Himalaya Exchange (HEX) and can be accessed using the HID# above. B. I am submitting this affidavit pursuant to 21 U.S.C. § 853(n) and Federal Rule of Criminal Procedure 32.2(c), asserting my lawful interest in the forfeited property in United States v. Ho Wan Kwok a/k/a "Miles Guo" (Case No. 23-cr-118 (AT) (S.D.N.Y.)). C. I am the lawful owner of the property, which is held as stablecoin reserves by the Himalaya Exchange. I have no knowledge of, nor did I participate in, any illegal activities,
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 37 of 64 and I acquired my assets in good faith as an innocent investor. D. I authorize FormerFedsGroup.Com LLC to continue to act on my behalf, actively pursue this claim, and seek the recovery of the equivalent amount of my HDO balance, as well as any relevant losses related to the depreciation of my HCN assets, as described below. According to bank records and HEX accounts, these purchases were made after it opened in April 2021 and before the U.S. government's seizure in September 2022. 2. Description of Forfeited Property A. The detailed information of the forfeited property is stored in HEX's account records, containing the Himalaya Dollar (HDO) stablecoin balance and the related Himalaya Coin (HCN) balance. HDO stablecoin reserves were seized or frozen as part of the government's forfeiture action in the above-mentioned case, amounting to millions of dollars, originating from Himalaya Exchange's bank accounts. B. My HDO balance represents a stablecoin investment intended as a secure, U.S. dollar-pegged asset, while my HCN holdings are associated with the platform's trading ecosystem. The seizure caused these assets to severely depreciate and become inaccessible. C. The government's seizure of the HEX platform and website rendered me unable to access my account information, but HEX has authenticated me as a customer and provided the account value of HDO, HCN, deposits,
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 38 of 64 and redemptions. I authorize my attorney to provide this information. 3. Basis for Claim A. My claim is based on the lawful interest in the following property: I am the lawful owner of the property, namely the USD amount equivalent to my HDO balance from the seized stablecoin reserves, and my right is superior to the government's forfeiture proceedings. My interest is superior to any government claim because I acquired the property in good faith and without knowledge of any forfeitable acts prior to the occurrence of the relevant crimes. The property was acquired lawfully, as detailed in HEX records, including transaction history, deposits, and account statements, demonstrating I did not participate in any alleged fraud scheme. All documents establishing my ownership interest and account history are stored in HEX records, which I authorize to be released under secure conditions. B. As an innocent owner under 21 U.S.C. § 853(n)(6), I have no knowledge of any illegal activities related to the property, nor is there reasonable cause to believe so. I invested in HEX believing it to be a legitimate cryptocurrency exchange providing HDO (stablecoin) and HCN (trading token) to achieve borderless financial freedom, as publicly advertised. C. Specific losses related to HDO assets: The government's seizure caused the exchange to halt redemptions because it no longer possessed the reserve
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 39 of 64 funds. Prior to the forfeiture, customers were able to submit redemption requests and convert HDO to USD. I seek to recover the equivalent amount of my HDO balance (as a stable asset) from the seized USD reserve funds of the Himalaya Exchange. D. Specific losses related to HCN assets: The government's seizure and the subsequent depreciation of HCN (Himalaya Coin) caused direct financial harm. Prior to the forfeiture, HCN held value as part of the HEX ecosystem, but the platform's trading halt and asset freeze resulted in a loss of value. I seek compensatory damages from the government for the loss of my HCN balance, calculated at the market price at the time the Himalaya Exchange suspended trading. 4. Compliance with Forfeiture Procedures A. I am submitting this claim by the statutory deadline required under 21 U.S.C. § 853(n)(2). B. I request the court to schedule an ancillary hearing pursuant to 21 U.S.C. § 853(n)(4)-(5) and Fed. R. Crim. P. 32.2(c) to adjudicate my claim, present evidence of my innocent ownership, and challenge the applicability of the forfeiture to my assets. C. If the court denies this ancillary petition, I submit the following statements in support of a petition for remission submitted to the Department of Justice, pursuant to 28 C.F.R. Part 9 (regulations governing the remission or mitigation of administrative, civil, and criminal forfeitures). I am an innocent owner with a
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 40 of 64 legitimate financial interest in the forfeited property, acquired without knowledge of the fraud. I request the Department of Justice to exercise its discretion to grant remission or mitigation of the forfeiture, noting that forfeiture procedures were not originally designed to handle overseas crypto exchanges like HEX, resulting in disproportionate harm to innocent users. I request the return of all funds held by HEX, including the equivalent amount of my HDO balance, without the use of a claims administrator to save costs and improve efficiency. I have not been defrauded by the Himalaya Exchange. The only loss caused is due to government seizure and actions, resulting in the exchange halting trading. 5. Relief Requested A. I respectfully request the court under this ancillary petition to: recognize my valid and superior property interest as an innocent third party; exclude my claimed property from the government's order of forfeiture, including releasing the USD equivalent of my HDO balance; and grant any other relief the court deems just and proper, such as an evidentiary hearing or discovery of HEX records to verify my claim. B. If the court does not grant this ancillary petition, please accept this as a petition for return and remission under the U.S. Department of Justice's remission procedures. I request not to use a claims administrator to save costs. I grant access under terms agreed upon by the Department of Justice and HEX,
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 41 of 64 employing the strictest security procedures to protect my information, given the overseas nature of the exchange If the court denies this ancillary petition, I submit the following statements in support of a petition for remission submitted to the Department of Justice, pursuant to 28 C.F.R. Part 9and potential privacy and other severe risks. I seek full remission, including my… 6. Authorization A. I authorize HEX to provide my account information to the court, the government, or a designated third party for review, subject to protective conditions to ensure my identity is not made public, thereby protecting my safety. B. I authorize FormerFedsGroup.Com LLC to represent my legal interests, continue to pursue the claim, and act on my behalf in all related proceedings. C. I authorize the court, the government, or a designated third party to return the funds, directly or through a third party coordinated by HEX. I understand the final procedure will be approved by the court, and I request it consider the crypto nature of the assets (e.g., converting to fiat equivalent at the seized value to mitigate loss). I declare under penalty of perjury that the foregoing information is true, correct, and complete to the best of my knowledge and belief. By entering my HID# and selecting "Submit," I confirm my identity and authorize the verification of this statement through my HEX account records.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 42 of 64 Submit
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 43 of 64 [Translator's Note: True and Correct English Translation of the Chinese Audio Exhibit 2A (Duration: 1m39s)] Forest Zhou (Government Witness): This is considered an important notice. Jiajia: Yes, exactly. Originally this should have been notified to the 1,800 creditors, but now only a few people were notified. So now, the Alliance is stepping in to bridge this information gap... Ava Chen: ...to communicate this information gap to all the fellow fighters who are already creditors. Because nobody is going to stare at this every day, considering there are five or six thousand [documents] and over 400 adversary proceedings. So nobody is going to type on their keyboard every day checking for documents. This has a potential direct impact on the interests of the creditors. Yes, because the fees will be deducted from the assets of the debtor, Mr. Wengui. So this will affect the remaining funds distributed to all creditors. If you are interested, please check the Alliance's upcoming announcement. Forest Zhou: To prevent individuals with ulterior motives from taking things out of context, we have a disclaimer here... It simply states that the Alliance is here to assist every fellow fighter, every creditor... to share the summarized information we obtained from consulting many lawyers... This is our disclaimer, right? The disclaimer will not be included in the screenshots.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 44 of 64 [Translator's Note: True and Correct English Translation of the Chinese Audio Exhibit 2C (Duration: 4m13s)] Ava Chen: I will briefly explain what this is. Recently, there have been some updates in our Connecticut bankruptcy case... Because the court documents were not served to each of the approximately 1,800 creditors, and only a few creditors were notified, we want to inform everyone here. If you are a fellow fighter who has already registered as a creditor... and you are interested in understanding this latest motion regarding the payment of the Trustee's fees... the Alliance here will help coordinate everyone, translate some documents, and share the latest information. You can immediately contact your Farm Owner or CEO... The deadline for filing an objection is April 17 EST... The Alliance has tentatively scheduled an information meeting for tomorrow night EST... Forest Zhou: I actually want to add something here... The trustee... has already burned through 70 or 80 million... we are providing this assistance so everyone understands the process... If you have this intention, the Alliance will assist everyone. Ava Chen: I want to add that after our broadcast, we will issue an Alliance announcement... containing both Chinese and English versions.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 45 of 64 Case No.: 1:23-cr-00118-AT EXHIBIT N Exhibit N: AI-forged audio recording of a fabricated prison phone call involving a microwave incident and a Christmas meal to misrepresent prison conditions. [Filed Under Seal & Ex Parte]
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 46 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 47 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 48 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 49 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 50 of 64 Case No.: 1:23-cr-00118-AT EXHIBIT O Exhibit O: AI-forged audio recording (May 2025) featuring Qingteng promoting TDCCP crypto and disseminating fabricated narratives of an absurd prison lifestyle. [Filed Under Seal & Ex Parte]
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 51 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 52 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 53 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 54 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 55 of 64 Case No.: 1:23-cr-00118-AT EXHIBIT P Exhibit P: Video Broadcast (Aug 18, 2025) featuring Qingteng and Jiajia coordinating the submission of petitions to assist the prosecution's asset confiscation objectives. [Filed Under Seal & Ex Parte]
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 56 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 57 of 64 hello@translayte.com +44 (0) 208 629 1290 BDXL Ltd. (No. 7496682). VAT No. 119597575. Registered Office: 20 - 22 Wenlock St. London. N1 7GU. United Kingdom.
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 58 of 64 Case No.: 1:23-cr-00118-AT EXHIBIT Z Exhibit Z: Official Court Record (Dkt. 833) documenting prosecutorial framing by attributing the criminal acts of "Hijackers" to the defendant to justify sentencing. [Filed Under Seal & Ex Parte]
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 59 of 64
family at the wedding of one of his daughters, where the Trustee’s three daughters were circled in red10: (GX 1B124F; see also Tr. 4717). Beyond the targeting and attempted intimidation of the Trustee and his family, Guo ordered others to obstruct the court proceedings in other ways. When Ya Li received a subpoena from the bankruptcy trustee, Guo told her to “throw it in the rubbish bin,” and she complied because she believed Guo when he said that the U.S. Department of Justice had been “weaponized by the CCP.” (Tr. 1498-99). In connection with the G Enterprise’s efforts to keep assets outside the reach of the bankruptcy trustee even after Guo’s arrest, Yongbing Zhang—the attorney and co-conspirator who “won” a Lamborghini in the G|CLUBS “sweepstakes,” and with whom Guo who has continued to 10 The red circles highlighting Despins’s daughters appeared on the photograph that was recovered from Guo’s cellphone. The Government added only the black redactions, to protect the privacy of victims and/or third parties in this public filing. 26
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meet in the MDC following his arrest and detention—asked Ya Li to sign a false affidavit for filing in one of the bankruptcy litigations. (Tr. 1523-29; GX VI 66). When she refused, Zhang threatened Ms. Li with $38 million in liability. (Tr. 1530). After this threat from Guo’s attorney, Ms. Li contemplated suicide. (Tr. 1530-31). More recently, Guo’s enterprise continues to harass and threaten those that oppose it. On March 10, 2026, in a video provided to the Government by a victim, Guo’s NFSC presenters requested that Guo’s remaining followers provide statements to Guo’s court appointed counsel. In addition, the presenter indicated that the 126 victims who previously provided statements “will all have to bear the consequences.” (Dkt. 832, Stmt. 206-B (translated)). That appears to be a reference to the 126 victim statements filed with the Court on November 22, 2024. (Dkt. 477). 3. Guo’s Post-Arrest Obstruction Even after his arrest Guo has engaged in obstructive conduct. Guo’s criminal Enterprise continued to operate following his arrest and Guo continued to direct it as it relocated to the UAE, outside the reach of U.S. law enforcement. (PSR ¶¶ 103-105). Following his arrest, Guo’s 27
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followers sought to fabricate evidence at the Mahwah Mansion to make it appear as if it were a G|CLUBS property, rather than Guo’s personal family home. (PSR ¶¶ 91-95). Similarly, following Guo’s arrest, one of Guo’s top lieutenants, Brother Long Island, instructed Ya Li and others to delete evidence from their phones in case they were arrested.11 (Tr. 1500-02). IV. VICTIM STATEMENTS To date, the Government has received and provided to the Court a total of approximately 225 victim impact statements. These statements reflect the extreme harm perpetrated by Guo on hundreds of victims located throughout the United States, harm that included extreme financial hardships, mental anguish, broken family bonds, and contemplation of self-harm including suicide. Specifically, on November 22, 2024, the Government filed a letter attaching approximately 126 victim statements. (Dkt. 477). On December 11, 2024, the Government filed seven additional victim statements that it had received. Dkt. 482. On January 2, 2025 and January 3, 2025, the Government filed a total of 16 additional victim statements. (Dkts. 486, 487). The Court has sealed dockets 477, 482, 486, and 487, which entries contain the aforementioned statements. On April 7, 2026, the Government filed an additional 74 statements under seal. (Dkt. 832). These cover letters are provided to the Court as an Exhibit, under seal, in light of the Court’s prior ruling.12 For the Court’s convenience, the Government will provide a hard copy of all of these victim impact statements to the Court’s chambers. 11 Prior to Guo’s arrest, Guo himself instructed Ya Li and others to delete evidence from their phones. (Tr. 1500-02). 12 The Government believes that the cover letter at Docket 477, which is attached under seal as Exhibit A to this filing, should be filed on the docket. That cover letter does not contain any personally identifying information for any victims. It merely summarizes certain statements received as of that date. Accordingly, the Government respectfully requests permission to file that letter on the docket. 28
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committed through Guo’s complex fraud, money laundering, and racketeering enterprise—or the verdict rendered by an impartial jury during the trial presided over by this Court. In assessing specific deterrence and protection of the public, the Court should weigh heavily that the defendant has never accepted responsibility for his truly offensive and blatant fraud. But Guo’s rejection of responsibility is worse than just that. A defendant is entitled to claim innocence but Guo goes further: he falsely claims victimhood. He attempts to denigrate the rule of law that brought him to justice. Such indignancy coupled with Guo’s baseless suggestion of impropriety in the prosecution of this case warrants a substantial sentence. See, e.g., Raniere, Dkt. 966 at 16 (“To make matters worse, [the defendant] and his counsel . . . are engaged in a public relations campaign to cast doubt on the integrity of the judicial system and the jury verdict.”). Third, perhaps most troubling is that Guo, and his enterprise, have continued criminal activities for the three years that Guo has been incarcerated. Following his arrest and detention, Guo continued to direct his enterprise as it relocated to the United Arab Emirates (UAE), outside the reach of U.S. law enforcement. (PSR ¶¶ 103-105). Victims who have monitored the online musings of Guo and his remaining acolytes further illustrate how Guo continues to operate his enterprise, and uses it stifle victims from speaking out against him: • “According to Yue Zhou, the Secretary-General of the New Federal State of China (NFSC), in the weekly ‘Until We Meet Again’ program every Friday, he and several other key members visit Ho Wan Kwok every week. Many of the orders currently being executed by NFSC have been approved by Kwok.” Dkt. 832, Stmt. 214. • “Despite the arrest of Guo Wengui, the fraud group has not been dismantled. The farms related to it are still operating, and Guo Wengui is still directing members in prison, instructing them to continue to defraud and threaten victims. In addition, members of the fraud gang are lurking in different countries and are still continuing to defraud, launder money and cover up crimes.” Dkt. 832, Stmt. 188. 67
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 63 of 64 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK In re: BAO CHU, Appellate Case No. 26-1296 Applicant. District Court Case No. 1:23-cr- 00118-AT Hon. Analisa Torres CERTIFICATE OF OMNIBUS SERVICE I,BaoChu, proceedingProSe, herebycertifyunderpenaltyofperjurypursuant to 28 U.S.C. § 1746 that on June 15, 2026, I served a true and correct copy of the “EMERGENCYMOTIONTOSTRIKESENTENCINGMEMORANDUM(DKT.833)INITS ENTIRETY,COMPELARULE104EVIDENTIARY(FATICO)HEARING,ANDISSUERULE 17(c)SUBPOENAS”,alongwiththeFormT-1080MotionInformationStatement,and Ten (10) Objective Evidentiary Exhibits (Exhibits 1 through 10). Service was effected concurrently via Electronic Mail to ensure immediate re- ceiptandtostrictlysatisfytherequirementsofOmnibusServiceuponallpartiesof record and statutory oversight entities: 1. Appellate Court (Second Circuit) Clerk of Court, U.S. Court of Appeals for the Second Circuit Email: prosecases@ca2.uscourts.gov 2. District Court (S.D.N.Y.) Hon. Analisa Torres, U.S. District Court, S.D.N.Y. Email: Torres_NYSDChambers@nysd.uscourts.gov; ProSe@nysd.uscourts.gov 3. Counsel for the United States (Prosecution) Micah Fergenson, Ryan Finkel, Juliana Murray, Justin Horton Assistant United States Attorneys, S.D.N.Y. Email: micah.fergenson@usdoj.gov; ryan.finkel@usdoj.gov; juliana.murray@usdoj.gov; justin.horton@usdoj.gov 1
Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 64 of 64 4. Counsel for the Defendants (Defense) John F. Kaley, Esq. Email: jkaley@doarlaw.com (And all relevant defense counsel of record via ECF/email correlation) 5. Statutory Oversight Entities (Pursuant to 28 U.S.C. § 1651) DOJOfficeoftheInspectorGeneral(OIG)&OfficeofProfessionalResponsibil- ity (OPR) U.S. House Judiciary Committee (Select Subcommittee on Weaponization) I declare under penalty of perjury that the foregoing is true and correct. Executed on June 15, 2026. Respectfully submitted, /s/ Bao Chu Bao Chu Applicant Pro Se / Bona Fide Third-Party Property Owner Standing Confirmed via S.D.N.Y. HID: F56BDDZ 2
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