---
type: court_doc
id: "court_2cir_26-1296_dkt_32"
court: "2Cir"
case_no: "26-1296"
doc_number: 32
doc_type: "MOTION"
filed_date: "2026-05-22"
lang: "zh"
url: "https://mubeitech.com/court/court_2cir_26-1296_dkt_32"
json_url: "https://mubeitech.com/api/court/court_2cir_26-1296_dkt_32"
---
# 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

**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，顶部为中文摘要。

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

Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 7 of 64

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

Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 8 of 64

EXHIBIT C

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Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 11 of 64

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

Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 12 of 64

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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Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 15 of 64

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
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50th Ave Apt 2p 51st Ave
51st
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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.
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Email
Website
Content
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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,
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OPENGOVNY Contact

Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 21 of 64

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

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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
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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
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. 个9S 88 合55 33 法(( n 的0 )) 加(( 66 密)) 下 货下的 币的干 交无
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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

Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 60 of 64

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 61 of 64

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

Case: 26-1296, 06/15/2026, DktEntry: 32.1, Page 62 of 64

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