---
type: court_doc
id: "court_ctb_404_30"
court: "CTB"
case_no: "22-50073"
doc_number: 404
doc_type: "EXHIBIT"
filed_date: "2022-05-20"
lang: "zh"
url: "https://mubeitech.com/court/court_ctb_404_30"
json_url: "https://mubeitech.com/api/court/court_ctb_404_30"
---
# EXHIBIT PAX 30 Deposition Transcript of Wengui Guo, *Guo v. Guo*, Case No. 18-cv-01064 (E.D. Va.)
> 原始法庭文件为英文；下方为英文全文，顶部为中文摘要。
## **EXHIBIT PAX 30**
Deposition Transcript of Wengui Guo, *Guo v. Guo*, Case No. 18-cv-01064 (E.D. Va.)
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IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA - - - - - - - - - - - - - - - - x WENGUI GUO, : Plaintiff, : vs. : Case No. 1:18-CV-01064-TSE-IDD BAOSHENG GUO, : Defendant. : - - - - - - - - - - - - - - - - x January 23, 2019 Washington, D.C. VIDEO DEPOSITION OF: WENGUI GUO Was called for examination by counsel for the Defendant, pursuant to notice, in the offices of, Zechner, Ellman & Krause, 409 7th Street, N.W., Suite 300, Washington, D.C., commencing at 10:08 a.m., before Carolyn Friend, a Notary Public in and for the District of Columbia, when were present on behalf of the respective parties:
703-780-9559 Misty Klapper & Associates
703-780-9559 Misty Klapper & Associates Page 2 APPEARANCES: J. DAVID MORRISSY, ESQUIRE Zeichner, Ellman & Krause, LLP 409 7th Street, N.W., Suite 300 Washington, D.C. 20004 (202) 783-0316 dmorrissy@zeklaw.com COUNSEL FOR THE PLAINTIFF JOHN C. ALTMILLER, ESQUIRE Pesner Kawamoto, PLC 7926 Jones Branch Road, Suite 930 McLean, Virginia 22102 (703) 506-9440 jaltmiller@pesnerkawamoto.com COUNSEL FOR THE DEFENDANT ALEXANDER LAUFER, ESQUIRE Eisenhower & Laufer, P.C. 10560 Main Street, Suite 218 Fairfax, Virginia 22030 (703) 352-9690 alex.laufer.elpc@gmail.com COUNSEL FOR THE DEFENDANT ALSO PRESENT: Helen Cole, Interpreter; David Voigtsberger, Video Operator; Una Wilkinson, Check Interpreter; Daniel Podhaskie C O N T E N T S WITNESS: EXAMINATION BY: PAGE: Wengui Guo Mr. Altmiller 4 703-780-9559 Misty Klapper & Associates Page 3 E X H I B I T S NO.: DESCRIPTION: PAGE: 1 Web page 75 2 Copy of photographs 80 3 Certification of translation 83 4 New York Times article 105 5 Answers to Interrogatories 107 6 Request for Production of Documents 111 703-780-9559 Misty Klapper & Associates Page 4 P R O C E E D I N G S (Whereupon, a statement was read by Video Operator.) MR. ALTMILLER: John Altmiller. I represent the Defendant, Baosheng Guo. MR. MORRISSY: David Morrissy from Zeichner, Ellman & Krause. We represent the Plaintiff, Deponent. (Whereupon, the Interpreter was sworn.) Whereupon: WENGUI GUO, Was called for examination, and, after being duly sworn, was examined and testified as follows: EXAMINATION BY COUNSEL FOR DEFENDANT BY MR. ALTMILLER: **Q Would you, please, state your name?** A Guo Wengui. **Q And is that your current legal name?** A The legal name is Guo Haoyun. It's Hong 703-780-9559 Misty Klapper & Associates Page 5 Kong pronunciation, Guo Haoyun. **Q And that is the name that is on your Hong Kong passport; is that correct?** A Yes. **Q And where do you currently live?** A New York, 5th Avenue, Number 781. **Q And how long have you lived there?** A Four years. **Q And where did you live before then?** A Well, correction, a little bit over three years, less than four. **Q And before then?** A Hong Kong, Beijing and London. **Q So what should I -- how should I address you?** A Just call me Guo Wengui. **Q Guo Wengui?** A Yes. **Q I will try and pronounce it correctly. Have you ever been deposed before?** A Yes. **Q How many times?**
Case 22-50073 Doc 404-30 Filed 05/20/22 Entered 05/20/22 11:52:18 Page 4 of
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| 1 | A | Three times. | 1 | account? | |
| 2 | Q | And when were those three times? | 2 | A | I don't know. |
| 3 | A | In September and November of 2018. | 3 | Q | Okay. And when did that happen? |
| 4 | Q | And those were the only times, in | 4 | A | So it stopped -- was stopped in October |
| 5 | | September and November? | 5 | | 2017 and lasted until about August or September of |
| 6 | | MR. ALTMILLER: Did he say? Sorry. | 6 | | 2018. Thank you. |
| 7 | | THE WITNESS: Approximately in November. | 7 | | MR. ALTMILLER: I'm sorry. Is the |
| 8 | | I don't remember the exact date. | 8 | | witness saying that's how long it was suspended or |
| 9 | | BY MR. ALTMILLER: | 9 | | how long he had the account? |
| 10 | Q | Since I don't know how those depositions | 10 | | THE WITNESS: I opened the Twitter |
| 11 | | were conducted, let me say that if you don't | 11 | | account in February of 2017. I used it for six or |
| 12 | | understand a question that I'm asking, you can ask | 12 | | seven months and some function was stopped in |
| 13 | | me to rephrase it. | 13 | | October of 2017. And by August and September of |
| 14 | | If you do not know the answer to a | 14 | | 2018, the entire account was closed. |
| 15 | | question, you can tell me that you don't know the | 15 | | BY MR. ALTMILLER: |
| 16 | | answer. I am not asking you to guess. | 16 | Q | Okay. Do you have any -- actually, let |
| 17 | A | Okay. Thank you. | 17 | | me -- I'm going to withdraw that question. How many |
| 18 | Q | If you need to take a break, that's fine. | 18 | | followers did you have on Twitter at the time the |
| 19 | | We surely almost certainly will be taking some | 19 | | account was suspended? |
| 20 | | breaks, but if you need to take a break, you can let | 20 | A | 450,000. |
| 21 | me know. | | 21 | Q | And do you have any YouTube channels? |
| 22 | A | Thank you. | 22 | A | Yes, I do. |
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| 1 | Q | I only ask that we not take a break when | 1 | Q | How many? |
| 2 | | there is a question pending. | 2 | A | One. |
| 3 | A | Thank you. | 3 | Q | And what is the name on that YouTube |
| 4 | Q | Have you been a party to any other | 4 | channel? | |
| 5 | | lawsuits in the United States? | 5 | A | I do not remember the registered number, |
| 6 | A | Yes. | 6 | | but the name of the channel is Guo Wengui. |
| 7 | Q | And do you know how many lawsuits you | 7 | Q | Guo Wengui. Okay. Do you have any |
| 8 | | have been a party to in the United States? | 8 | | channels under the Miles Kwok? |
| 9 | A | Approximately 30 plus something. Some I | 9 | A | So I don't quite remember this name. |
| 10 | | am the Plaintiff, some I am the Defendant. | 10 | | There were many accounts under YouTube that used my |
| 11 | Q | Okay. The first thing that I'm -- or the | 11 | | name. Some were registered by my supporters. Some |
| 12 | | first topic that I'm going to ask you about is going | 12 | | were registered by my colleagues. Some of them were |
| 13 | | to be about social media. So I'm going to try and | 13 | | registered by my Nemesis, people in the communist |
| 14 | | break this deposition up into topics so that I'm not | 14 | | parties. So a lot of people registered to YouTube |
| 15 | | jumping from -- from thing to thing. | 15 | | account with my name. |
| 16 | | Do you have a Twitter account? | 16 | Q | Okay. So what I want to ask about are |
| 17 | A | Used to. | 17 | | YouTube channels on which you post videos. I |
| 18 | Q | And when did you stop having a Twitter | 18 | | don't -- I'm not asking about people who might take |
| 19 | account? | | 19 | | your name and use it for -- for bad reasons, but |
| 20 | A | I did not close it. Twitter closed my | 20 | | just where you post videos. |
| 21 | account. | | 21 | A | Yes, then I know the Chinese name is Guo |
| 22 | Q | Do you know why Twitter closed your | 22 | Wengui. | |
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| 1 | Q
Okay. Thank you. And how many | 1 | A
For sure. |
| 2 | subscribers are there to that channel? | 2 | Q
Okay. Do you have your own website? |
| 3 | A
Used to reach about 260,000 and it | 3 | A
No. |
| 4 | dropped to about 200,000. Right now it's 197,000. | 4 | Q
Have you ever had your own website? |
| 5 | Q
Okay. And how often do you put out | 5 | A
Website, web page. I don't recall that I |
| 6 | videos on your YouTube channel? | 6 | have that. |
| 7 | A
Sometimes three or four times per week. | 7 | Q
Okay. Is -- is -- I'll go back to that. |
| 8 | Sometimes two or three times per day. Varies. | 8 | I'm going to move to a new subject. Do you make |
| 9 | Q
And what are the videos about? | 9 | public speaking appearances? |
| 10 | A
Against the -- China's Communist Party, | 10 | A
Yes. |
| 11 | support the -- the legal freedom and the religious | 11 | Q
Do you know about how often you make |
| 12 | freedom. Also, against the spies that's sent out to | 12 | public speaking appearances? |
| 13 | the United States by the communist party. | 13 | A
Not often. |
| 14 | Q
And the communist party, the Chinese | 14 | Q
And would it be fair to say that at these |
| 15 | Communist Party sends spies to the United States; is | 15 | public speaking appearances you talk about the same |
| 16 | that correct? | 16 | things that you would talk about in your videos with |
| 17 | A
I don't understand your question. Is it | 17 | regard to protection of the United States and for |
| 18 | related to today's subject matter? | 18 | democracy in China? |
| 19 | MR. MORRISSY: It calls for speculation | 19 | MR. MORRISSY: Is that what he said, that |
| 20 | as well. Well, you're asking him about whether a | 20 | it -- is that what the testimony said previously? |
| 21 | country sends spies into our country? | 21 | MR. ALTMILLER: I thought that what he |
| 22 | MR. ALTMILLER: Well, he -- | 22 | said was that he speaks to people who -- he speaks |
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| 1 | THE WITNESS: You seem to know. | 1 | against Chinese -- |
| 2 | MR. ALTMILLER: Well, he -- he said that | 2 | |
| 3 | he speaks against the spies that the Chinese sends, | | MR. MORRISSY: In support -- in support |
| 4 | | 3 | of a safe United States and against the CCP. |
| | so, perhaps, the answer is self-evident. I -- I | 4 | MR. ALTMILLER: Yes. |
| 5 | don't need to go down that road, particularly, very | 5 | MR. MORRISSY: Okay. |
| 6 | far, so I'm going to withdraw the question because I | 6 | MR. ALTMILLER: That was my understanding |
| 7 | don't -- I don't think it's -- it's not going to | 7 | of what the videos are about. |
| 8 | advance anything. | 8 | MR. MORRISSY: Right. No. I just |
| 9 | BY MR. ALTMILLER: | 9 | believe the question framed it a little bit |
| 10 | Q
Who -- to whom are your videos directed? | 10 | differently. |
| 11 | Who are you speaking to in your videos? | 11 | MR. ALTMILLER: Oh, okay. Well, I can -- |
| 12 | A
My audience are for all of those who | 12 | I'll frame it that way. That's certainly what I -- |
| 13 | support a safer United States and those who -- | 13 | how I intended to frame it, was whether or not |
| 14 | against communist party, CCP. | 14 | the -- the speaking appearances are about those same |
| 15 | Q
And how many people view these videos? | 15 | things, about the protection of the United States |
| 16 | A
You are talking about every time or | 16 | and -- and against the communist government in |
| 17 | ballpark? | 17 | China. |
| 18 | Q
What -- how about this: The video that | 18 | THE WITNESS: Of course. |
| 19 | the most people saw, how many people saw that video? | 19 | BY MR. ALTMILLER: |
| 20 | A
I don't remember. | 20 | Q
Have you been -- have your activities |
| 21 | Q
Have you had videos that a million people | 21 | been covered by the media? |
| 22 | saw? | 22 | A
Yes. |
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| 1 | Q
Do you consider yourself to be a public | 1 | Chinese people, hoping China can become a -- a -- a |
| 2 | figure? | 2 | rule of law country as being fair and have religious |
| 3 | A
No. | 3 | freedom. |
| 4 | Q
Was there a profile done of you in the | 4 | So -- and no spies are sent to the |
| 5 | New York Times? | 5 | Western countries to corrupt the society. So I do |
| 6 | A
Yes. | 6 | not understand your question. |
| 7 | Q
And you cooperated with that? | 7 | MR. ALTMILLER: So my question is that |
| 8 | A
I do not understand cooperate means. I | 8 | the -- the goals that he is seeking to accomplish |
| 9 | was interviewed by them. When someone interview | 9 | that he has just spoken about, I was just asking |
| 10 | you, do you consider that cooperate? | 10 | what he -- he -- he's doing to further that goal. |
| 11 | Q
I do consider it cooperation because you | 11 | That's all I'm asking. |
| 12 | have the right not to be interviewed. And so -- so | 12 | THE WITNESS: I don't understand. |
| 13 | my question is, did you agree to the interview? | 13 | BY MR. ALTMILLER: |
| 14 | A
Yes, yes, now I understand. I | 14 | Q
I have read media reports that you have |
| 15 | understand. Yes, the English is too high of a | 15 | been working with Steve Bannon and -- first of all, |
| 16 | caliber. Answer, yes. | 16 | is that correct? |
| 17 | Q
Okay. Have you spoken to -- well, let me | 17 | A
I don't want to answer questions that |
| 18 | rephrase that. Have you given other interviews to | 18 | third parties is involved. |
| 19 | the media? | 19 | MR. ALTMILLER: Okay. And let me just |
| 20 | A
Yes. | 20 | say for the record the reason I'm asking the |
| 21 | Q
And are -- is the purpose of these | 21 | question is actually I don't -- I don't care about |
| 22 | interviews to advance the cause that you speak in | 22 | the specifics about what they're doing, and I'll |
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| 1 | favor of on your videos and elsewhere? | 1 | proffer that the reason I'm asking the question is, |
| 2 | A
Yes. | 2 | obviously, one of our defenses relates to the |
| 3 | Q
Okay. And it would be fair to say that | 3 | witness being a public figure. |
| 4 | you've been politically active, would it? | 4 | And so since he says he's not a public |
| 5 | MR. MORRISSY: What -- can you be a | 5 | figure and I think that he's doing a -- it seems to |
| 6 | little more specific what that means? | 6 | me that he's doing a lot of work toward helping |
| 7 | MR. ALTMILLER: I guess we know what that | 7 | democracy in China that -- I just wanted to |
| 8 | means in the United States. I will -- I'll rephrase | 8 | establish I think he's doing a lot in that respect. |
| 9 | it. | 9 | In other words, he's posting videos, he's |
| 10 | BY MR. ALTMILLER: | 10 | meeting with people. At least I'm reading about |
| 11 | Q
Have you sought to achieve some of your | 11 | funds that he's creating, and I say this with no |
| 12 | goals through political means, that is to say by | 12 | dubiousness with regard to his intent. I just want |
| 13 | working with American politicians? | 13 | to establish that that's what he's doing, so that's |
| 14 | A
No. | 14 | why I'm asking what he's doing. |
| 15 | Q
Other than speaking engagements and -- | 15 | And if he doesn't understand what I mean |
| 16 | and -- and videos, what other activities have you | 16 | when I say what other things are you doing in order |
| 17 | engaged in for the cause against the communist | 17 | to -- to pursue this goal that is obviously very |
| 18 | government in China? | 18 | important, that he thinks about day and night, and I |
| 19 | A
I do not understand your question. I can | 19 | have no doubt that he does, then I have to start |
| 20 | tell you when I'm sleep, I think about that subject | 20 | asking specific questions. My preference would be |
| 21 | matter. Whatever I do, I think about that subject | 21 | not to, just to be clear. |
| 22 | matter. My goal is to save 14 -- 1.4 billion | 22 | So if there's any way to communicate that |
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| 1 | to the witness in a way that I can just get a very | 1 | the cause of democracy in China is posting videos |
| 2 | brief overview of what he's doing, that would solve | 2 | and making infrequent speeches, I'm totally fine |
| 3 | my problem very quickly. | 3 | with that. I just want to know that that's the |
| 4 | MR. MORRISSY: So it seems that you've | 4 | answer. |
| 5 | had a brief overview of what he's doing. Are you | 5 | THE WITNESS: We have done a lot of works |
| 6 | asking if there's anything outside of what you've | 6 | other than those two things to -- to go against the |
| 7 | spoken about that he's doing to advance his cause? | 7 | CCP. A lot of people's safeties are involved. A |
| 8 | MR. ALTMILLER: Right. In other words -- | 8 | lot of information is in the process of gathering. |
| 9 | and, again -- I'll say it again, that I -- I know | 9 | We also have a signed agreement with certain people |
| 10 | he's posting videos and I know he's speaking | 10 | not to disclose those information. So I think the |
| 11 | somewhat, and there's a very -- as I say, I have no | 11 | subject matter is not appropriate to be asked today. |
| 12 | doubt about his -- I personally am not expressing | 12 | I'll give you an example. We used to -- |
| 13 | any doubt about his sincerity. I'm just | 13 | contemplating establishing a legal fund to assist |
| 14 | presuming -- maybe I'm not presuming. I'm asking if | 14 | those who are being hurt by CCP, but because I'm a |
| 15 | there's anything other than posting videos. | 15 | donor, because of the role that I'm playing, I have |
| 16 | Is -- people who want to have political | 16 | no right to give a public speech. The information |
| 17 | solutions sometimes engage in political activity. | 17 | you want are the information CCP want. |
| 18 | People who want to fund things sometimes engage in | 18 | MR. ALTMILLER: Okay. Okay. I'll just |
| 19 | funding, they engage in organizing. There are all | 19 | say for the record, by the way, I do not want to |
| 20 | kinds of things that people do when they want to | 20 | help the CCP. |
| 21 | achieve a political goal, particularly one as -- as | 21 | THE WITNESS: But see the question you |
| 22 | noble as achieving democracy in China. | 22 | ask and what Guo Baosheng is interested in are very |
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2 | And given the -- the man's convictions
and his means, I'm -- I just -- I was just asking | 1
2 | similar to -- that you are on the side of CCP.
MR. MORRISSY: Very different. |
| 3 | what he's doing, and I'm proffering this has to do | 3 | MR. ALTMILLER: Well, I -- I'm going to |
| 4 | with whether or not he's a public figure. | 4 | make a distinction for the remainder of this |
| 5 | MR. MORRISSY: No. Understood. And so | 5 | deposition that I have no interest in pursuing the |
| 6 | we've -- you have the answer about the political | 6 | goals of the CCP, whatsoever. So -- in case |
| 7 | involvement, right, so -- | 7 | there's -- anybody is curious about that. I say as |
| 8 | MR. ALTMILLER: Well, he said -- yeah. | 8 | an officer of the court I have had no contact with |
| 9 | He says he's not engaged in any political | 9 | the CCP or anyone from China in connection with this |
| 10 | involvement, but I need to know what he's doing. | 10 | case other than my client and the gentleman that you |
| 11 | MR. MORRISSY: So that's -- so that's his | 11 | saw earlier. |
| 12 | answer. | 12 | MR. MORRISSY: Steven Taljeng? |
| 13 | MR. ALTMILLER: Right. | 13 | MR. ALTMILLER: Yeah. |
| 14 | MR. MORRISSY: So that's his answer | 14 | THE WITNESS: I am very appreciative of |
| 15 | relating to politics, so -- | 15 | what you just said. I hope that is the case. |
| 16 | MR. ALTMILLER: Well, let's get into | 16 | However, your questions is helping the CCP. |
| 17 | whether or not there's anything else. I just want | 17 | BY MR. ALTMILLER: |
| 18 | to know if -- | 18 | Q
If I ever ask a question, the answer to |
| 19 | MR. MORRISSY: Sure. | 19 | which will help the Chinese government, please let |
| 20 | MR. ALTMILLER: -- there's anything else | 20 | me know so that we all can steer clear of those |
| 21 | that he's doing. If the only thing that he's | 21 | questions because I don't think anybody in this |
| 22 | doing -- if the only thing that he's doing to help | 22 | room -- and I hope I don't get in trouble with the |
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703-780-9559 Misty Klapper & Associates Page 22 **Chinese government by saying this. I'm not interested at all in that issue, other than how it affects certain smaller discrete issues in this case. All right. I'm going to move to a different topic. How did you meet Baosheng Guo?** A I did not know that person prior to 2017 after I started to disclose the -- the -- or expose the ugly news of CCP in 2017, then he put out the video supporting my position. When I was in Washington, DC on a -- the -- the open -- the news conference, doing a news conference on October 3rd of -- press conference in Washington, DC on October 3rd of 2017 he appeared and we shook hands. Few months ago, sometime in 2018, I was in the DC hotel and we met for a couple of minutes, shook hands. That's it. CHECK INTERPRETER: The witness also said, I actually don't really know this person. THE INTERPRETER: I really don't know this person. 703-780-9559 Misty Klapper & Associates Page 23 BY MR. ALTMILLER: **Q So Baosheng Guo?** A Yeah, Baosheng Guo, yes. **Q Okay. The -- the press conference in 2018, what was that about?** A The purpose of that press conference was to expose two very important plans by the CCP. One is called -- one is called the BGY. One is called the BGY. The other is called the 3F. Those were the plans that communist party planned to send spies to the United States to destroy U.S. government. **Q Have you given other press conferences?** A During which time frame and what type of press conference? I also held a press conference on November 20th, 2018, which is to expose some truth about Hainan, HNA Group. CHECK INTERPRETER: Wang Jian. THE WITNESS: Wang Jian dies, the truth. BY MR. ALTMILLER: **Q Are you well known in China?** A How do you define well known? In the past or now? 703-780-9559 Misty Klapper & Associates Page 24 **Q How about now?** A I'm overseas. What I heard is that I was well known there. **Q When you lived in China, were you well known?** A No, I was not well known. **Q Okay. Are you well known in the Chinese community in the United States?** A I don't know your definitions of well known. **Q Okay. Okay. So you did not know -- you did not really know Baosheng Guo; is that correct?** A Correct. **Q Did you ever pay Baosheng Guo any money?** A I didn't pay him. He defrauded me. **Q Let me ask the question again. Did you ever transfer any funds to Baosheng Guo?** A Yes. **Q Why did you transfer funds to Baosheng Guo?** A That's the reason why we are sitting here today. He defrauded me. 703-780-9559 Misty Klapper & Associates Page 25 **Q How many times did you transfer money to Baosheng Guo?** A More than twice. I don't remember exact number. **Q Do you have any documents related to the transfer of any money to Baosheng Guo?** A Yes. **Q Have you produced those documents to -- to your attorney or to -- to me?** MR. MORRISSY: The deponent doesn't know what I've produced to you. BY MR. ALTMILLER: **Q Okay. Well, have you produced it to the -- to your attorney, then?** A I should have. MR. ALTMILLER: Okay. I don't know that I have any documents related to the transfer of funds. If I'm wrong about that, then you can correct me. MR. MORRISSY: Yeah, you -- you are. MR. ALTMILLER: Okay. Okay. Then I'll -- I'll move away from that.
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| 1 | BY MR. ALTMILLER: | 1 | are critical of you now. And that's the question. |
| 2 | Q
Other than the documents that have been | 2 | Are you -- well, let -- I'll do -- |
| 3 | provided to your attorney with regard to transfers | 3 | I'll -- I'll phrase it this way: Do you know why -- |
| 4 | to Baosheng Guo, do you have any other documents | 4 | I just don't want to get a foundation objection if |
| 5 | related to the transfer of funds to Baosheng Guo? | 5 | we agree since that's in the complaint. Do you know |
| 6 | A
Other documents? | 6 | why Baosheng Guo began posting critical statements |
| 7 | MR. ALTMILLER: I'm just asking if there | 7 | about you when he had previously been posting |
| 8 | were any documents other than what he's provided to | 8 | praiseworthy statements about you? |
| 9 | his attorney. That's all. | 9 | A
That is one or the first reasons that I |
| 10 | THE WITNESS: How about the voice | 10 | sue Mr. Baosheng Guo. The first reason I sued |
| 11 | conversation, the witnesses are they count as | 11 | Mr. Guo Baosheng was that I do not dispute the fact |
| 12 | others? | 12 | that he stated on the video that the police officers |
| 13 | BY MR. ALTMILLER: | 13 | and the -- the security people went to his hometown |
| 14 | Q
I was just referring to documents that | 14 | and found his mother at which time they offered his |
| 15 | related to the transfer of funds only, not -- not | 15 | mother \$30 million to \$80 million RMB for Mr. Guo to |
| 16 | other evidence. | 16 | turn against me for the purpose -- or for the things |
| 17 | A
Yes, some documents I already handed over | 17 | that I am doing, which is -- and that against the |
| 18 | to my attorney. | 18 | communist party. |
| 19 | Q
Okay. What was the purpose for | 19 | CHECK INTERPRETER: Also -- the witness |
| 20 | transferring funds to Baosheng Guo? | 20 | also said that apart from the 30 million -- the |
| 21 | A
The purpose of wiring those money was | 21 | check Interpreter believes the witness also stated |
| 22 | because he said he is going to -- to -- to hold a | 22 | apart from the 30 million, the 80 million RMB he |
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| 1 | conference that is catered to the people around the | 1 | also said that the -- the mother was also offered |
| 2 | world that support democracy and against CCP. He | 2 | luxury home. And also at the end of his statement |
| 3 | also said that he needed video related equipment, | 3 | also he mentioned that he is in -- in aid of helping |
| 4 | cell phones, the boom lights for the conference and | 4 | China to set up a rule of law and religious freedom. |
| 5 | some equipment related to that activity. And that's | 5 | THE WITNESS: Rule of law. So based on |
| 6 | why I was defrauded. | 6 | the information that he disclosed on the video, I |
| 7 | Q
Do you know if Baosheng Guo posted videos | 7 | don't think it is -- it is against me. I think it |
| 8 | in which he -- in which he said -- in which he | 8 | is insulting to me. Think about it; in the past one |
| 9 | praised you? | 9 | years he said nothing but supporting me, but all of |
| 10 | A
A lot of them. | 10 | a sudden 180 degree turn. |
| 11 | Q
And when did you become aware of those | 11 | He was a pastor, he was an author who can |
| 12 | videos that were praiseworthy of you? | 12 | turn in -- in that fashion so quickly, do you think |
| 13 | A
From the very beginning when he started | 13 | that's normal? |
| 14 | posting them, I was made aware. | 14 | BY MR. ALTMILLER: |
| 15 | Q
And do you know around what time that was | 15 | Q
So it is -- would it be fair to say that |
| 16 | when he started posting those videos that praised | 16 | it is your position that the reason that Baosheng |
| 17 | you? | 17 | Guo is now critical of you is because he's being |
| 18 | A
I don't remember exactly. | 18 | paid to be critical of you by the Chinese |
| 19 | Q
Okay. Do you know if there was a time | 19 | Government? |
| 20 | when -- well, let me rephrase that. You've | 20 | A
Based on my suspicion of him and his |
| 21 | alleged -- and I don't think it's in much dispute | 21 | abnormal activities, that he -- he was -- shows that |
| 22 | that there have been postings by Baosheng Guo that | 22 | he insulted and defrauded those who -- against the |
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703-780-9559 Misty Klapper & Associates Page 30 CCP. His attitude or his -- appears to be very close to CCP. He defrauded a lot of money out of those who -- against the CCP. That's the reason why I filed the lawsuit here. I hope the court of the United States can conduct an investigation and give us an equitable result. **Q When do you think Baosheng Guo turned on you and started making critical statements?** A I don't remember the exact time frame. I only remember the time happened when he said that the police and public security people visited his hometown, offered the family a -- a luxurious home and money. Right after that, he turned on me. You can find those information through media records. **Q Well, I'm -- I'm asking -- I'm asking you. It -- it seems that you have alleged that in June and July of 2018 Baosheng Guo began tweeting statements that were critical of you and upon which you are suing. I'm just trying to figure out whether or not he did anything earlier than that.** A The day and time were mentioned in our complaint, so I think that should stand. 703-780-9559 Misty Klapper & Associates Page 31 **Q That's -- that's fine. Did you ever have any agreements -- let me -- I'll be more specific. Have you ever had any written agreements with the Defendant, Baosheng Guo?** MR. MORRISSY: Do you mean, just to be clear, a formal contract or -- or do you mean -- MR. ALTMILLER: Yes. MR. MORRISSY: -- writing -- a communication between the two or how do you mean? MR. ALTMILLER: I mean any agreement that's memorialized in writing, whether it be a written contract or whether it be e-mails back and forth; I will do this if you do that. And an e-mail comes back and says I accept those terms or, you know, things to that effect. THE WITNESS: There are written papers, yes. We have some written papers. E-mail, yes. My partner sent him some e-mail -- e-mails, but I personally never sent him any e-mails. He did send me e-mails and all those information, some of them already provided to my attorneys. Some of them are in the midst of compiling. 703-780-9559 Misty Klapper & Associates Page 32 BY MR. ALTMILLER: **Q Okay. So there are e-mails from Baosheng Guo that have not yet been produced to your attorney; is that correct?** A No, no. All the e-mails I provided to my attorneys. What I was referring to are the voice recordings that are in the process of translating at the moment. I have not provided. However, all the original documents have been provided. **Q Okay. So there are some voice recordings that I don't have yet; is that correct?** MR. MORRISSY: No, that's not correct. MR. ALTMILLER: Okay. MR. MORRISSY: You have them. MR. ALTMILLER: Okay. Okay. So the witness is just incorrect? MR. MORRISSY: No. He -- what -- what the witness said was that he was in the process of translating them. MR. ALTMILLER: Okay. MR. MORRISSY: At least that's what the Interpreter said the witness said. 703-780-9559 Misty Klapper & Associates Page 33 MR. ALTMILLER: Okay. CHECK INTERPRETER: That's right, yeah. MR. ALTMILLER: Okay. All right. So of what's been provided, he's in the process of translating what's already been provided? Okay. That's fine. I just -- I just want to make sure that I know what I've got and what I don't. BY MR. ALTMILLER: **Q You had indicated earlier that Baosheng Guo had posted many videos that were praiseworthy of you prior -- well, first of all, did he post videos that were praiseworthy of you prior to meeting you?** A A lot of them. **Q How did he, Baosheng Guo, know who you were prior to meeting you?** MR. MORRISSY: That calls for speculation. THE WITNESS: Go ask Mr. Guo Baosheng. BY MR. ALTMILLER: **Q Okay. Did you ever pay any travel expenses of Baosheng Guo?** A Yes. I did not pay him. He defrauded
703-780-9559 Misty Klapper & Associates Page 34 me. He -- he applied for the travel fee from me. He also defrauded those who supported me for travel -- travel expenses, including those who are really poor. For example, people in Los Angeles that makes less than \$2,000 a month and he defrauded them for the travel expenses, such as airline ticket and then many times over. The travel fee he applied from me he did not spend it on travel and that is the second reason I'm suiing him today. He applied for the travel fee to be used on airplane, to get hotels and then also defrauded the people who supported me, including very poor people, and that's -- that's the second reason I'm suiing him. During his travel, whatever he eats, the meal expenses, the wine, the liquor that he drank were the -- were the -- were the money paid out by us and the people, poor people who supported me. Those who -- those people who go against the CCP, they against the CCP with their life. And he defrauded them of their livelihood, left them with very little money for food. And that is the second 703-780-9559 Misty Klapper & Associates Page 35 reason I have to sue him. So he says the reason for his travel was to support my mission of -- against the CCP. He travels to -- to California, to Las Vegas. The -- the travel expenses that he -- he applied was many times over than what he really spent. So he went to California. He used the name of helping people to seek political asylum, taking money from them and -- although he says his goal is to support our mission to go against the CCP, but he was doing exactly the opposite. And that is the third reason I have to sue him. So I make a recommendation to you, attorney, during the court proceedings that you can look for those peoples to come to the court as a witness, but please do keep in mind to protect their privacy and protect them, not to -- not to disclose -- protect their privacy and protect their safety. So -- so Mr. Guo -- Mr. Guo used the Twitter, exposed those people who were seeking the asylum, exposed their names and their informations, 703-780-9559 Misty Klapper & Associates Page 36 threatened those people -- threatened those people. So I think what he did is shameful and is terrible, and that's the reason why I'm suiing him for the fourth reason. I'm seeking -- the -- the third reason I'm suiing him in order to seek the fair treatment of those people that were seeking political asylum. CHECK INTERPRETER: The witness also mentioned that -- threatened those people with repatriation. THE INTERPRETER: That's correct, threatened those people with -- with repatriation. BY MR. ALTMILLER: **Q Okay. The -- Baosheng Guo represented to you that he was going to create a group whose goal it was to assist victims of the CCP, correct?** A To establish an organization to help those victims. **Q Of the CCP?** A Of the CCP, no, no. **Q Okay. Did -- did the Defendant represent to you -- did Baosheng Guo represent to you that he** 703-780-9559 Misty Klapper & Associates Page 37 **needed financial support to purchase video equipment in order to hold a conference and to take the first steps to create a group whose goal it was to assist the victims of the CCP?** A The event that you described did exist, but he was using that as an excuse that he wants to establish a Twitter party to -- and then host an entire CCP conference and using that as an excuse, asked me for 40,000 to 60,000 U.S. dollars. And that was one of the reasons I'm suiing him. **Q All right. So my -- the answer to my question, which was did Baosheng Guo represent to you that he needed financial support to purchase video equipment in order to hold a conference and to take the first steps to create a group whose goal it was to assist the billion victims of the CCP, the answer to that question, then, is yes, that he did make that representation to you?** A He asked money for -- for the video equipment, yes, but not for the conference, but for the direct broadcasting from the hotel. Correction, to pay for the hotel expenses, for direct
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| 1 | broadcasting and pay for hotel expenses. | 1 | MR. ALTMILLER: I agree with you; he |
| 2 | Q
And how did he make that representation | 2 | didn't say yes. He, in fact, clarified that he |
| 3 | to you? Was it verbally or was it over e-mail? | 3 | didn't say yes. What he said was that he -- that |
| 4 | A
Mr. Attorney, I want to make something | 4 | the -- that the -- Baosheng Guo had represented to |
| 5 | clear and maybe correct your question in the middle | 5 | him that he needed money to buy video equipment for |
| 6 | of it, is that from -- from day one, when I put out | 6 | some purpose that wasn't quite what I said. |
| 7 | the video -- videos on the Internet, I already | 7 | MR. MORRISSY: I believe -- yeah, it was |
| 8 | stated very clearly that I do not take any money | 8 | relating to a live -- |
| 9 | from anybody. I don't receive -- I don't want to | 9 | MR. ALTMILLER: A live stream, yeah. |
| 10 | take any donations because I am sick and tired of -- | 10 | MR. MORRISSY: -- stream from a hotel or |
| 11 | in the past 29 years, those overseas Chinese people | 11 | something like that, yeah. Okay. |
| 12 | using the -- the -- the excuse of donation, saying | 12 | MR. ALTMILLER: And -- and so let me -- |
| 13 | that they want to help those victims of -- of the | 13 | I'll -- |
| 14 | CCP. | 14 | MR. MORRISSY: I just want to be clear -- |
| 15 | And I want to make it very clear. Nobody | 15 | be clear about what's happening. |
| 16 | can represent me. I stated many, many times in an | 16 | MR. ALTMILLER: I'll clarify. Let me -- |
| 17 | open -- open forums or situations. Nobody can -- | 17 | let me clarify that. So I'll -- I'll ask the |
| 18 | can represent me. | 18 | question again. |
| 19 | The fourth -- the fourth reason that | 19 | MR. MORRISSY: Thanks. |
| 20 | I'm -- I'm suing him is because that Mr. Guo | 20 | MR. ALTMILLER: That will be fine. |
| 21 | Baosheng went to many places, including Canada, | 21 | BY MR. ALTMILLER: |
| 22 | Japan, Taiwan, California, Los Angeles, Las Vegas | 22 | Q
The representation that Baosho Gua -- |
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| 1 | stating that he -- and Japan and he -- stating that | 1 | excuse me -- Baosheng Guo made to you with regard to |
| 2 | he represented me by using representation of me to | 2 | needing money to buy video equipment for the purpose |
| 3 | defraud so many people and hurt so many people. | 3 | that you testified to, was that made verbally or was |
| 4 | I already told it in the public many, | 4 | it made in writing? |
| 5 | many times; I do not allow anybody to represent me. | 5 | A
Verbal. |
| 6 | I do not allow anybody to represent me. I told him | 6 | Q
And when was that representation made? |
| 7 | to his face, I do not allow you to represent me | 7 | A
June, July or maybe July, August of 2017. |
| 8 | because he used my name as a vehicle to defraud | 8 | I don't remember the exact time frame. |
| 9 | people and that is the fourth reason I'm suiing him. | 9 | Q
Was it over the phone or in person? |
| 10 | Q
The representation that Baosheng Guo made | 10 | A
I already told you we met -- we never met |
| 11 | to you that he needed financial support to buy video | 11 | face to face, so, of course, it's by telephone. |
| 12 | equipment, was that made verbally or by e-mail? | 12 | Q
Did he call you or did you call him? |
| 13 | MR. MORRISSY: Well, before he answers, | 13 | A
He called me. I never or seldom call |
| 14 | the -- before -- let's clarify that. What you said | 14 | him. He was the one who called me and said what's |
| 15 | before was compound, right, so you -- you asked him | 15 | up. Yes, so seldom, call -- |
| 16 | a question relating to video equipment and the | 16 | Q
Did he call on your cell phone? |
| 17 | conference in furthering, you know, furthering | 17 | A
Yes. |
| 18 | certain goals. | 18 | Q
And how did he get your cell phone |
| 19 | MR. ALTMILLER: Right, right. | 19 | number? |
| 20 | MR. MORRISSY: And so -- and then he said | 20 | A
We have WhatsApp. |
| 21 | what he said and you took it to mean, yes, but he | 21 | Q
Well, then, was -- was the -- was the |
| 22 | didn't actually say yes. | 22 | representation made via WhatsApp or was it made |
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703-780-9559 Misty Klapper & Associates Page 42 **for -- in a -- in a telephone call?** A You can use WhatsApp to make a phone call. **Q Oh, okay. I didn't know that. I'm not particularly text savvy. All right. Did -- did Baosho -- Baosheng Guo represent to you that he needed \$20,000 to purchase broadcasting equipment for a group whose goal it was to assist victims of the CCP?** A He asked for money for the equipment for the direct broadcasting. He did not said for the purpose of helping the victims of the CCP. CHECK INTERPRETER: The witness said that -- he stated the purpose is for anti-CCP, but he did not state it is helping the victims prosecuted by the CCP. MR. ALTMILLER: That is to say, when you say he, you mean, Baosheng Guo didn't represent that it was for the help of victims of the CCP; it was instead for this NTCCP, which is -- MR. MORRISSY: Anti. MR. ALTMILLER: Anti. Oh, anti -- 703-780-9559 Misty Klapper & Associates Page 43 anti-CCP. I -- I understand now. Sorry. THE WITNESS: Correct. BY MR. ALTMILLER: **Q Okay. And how was that representation made? Was it made verbally or in writing?** A Verbal. **Q And do you -- did you give him that \$20,000?** A For that particular time maybe 10,000 I gave it -- to him, you know, back and forth several times. **Q And when we discussed the video equipment a few minutes ago, did you give him money for video equipment?** A Yes. **Q And how much did you give him?** A I don't remember the exact amount. It may be more than 10,000. **Q And you believe that the money that you gave to him in connection with video equipment and the broadcasting that you just testified to that he did not use it for the purpose that he said he was** 703-780-9559 Misty Klapper & Associates Page 44 **going to use it?** A That's the fifth reason I'm suiing him. He asked me for money to establish social media to go against the CCP, but as a token, he went to Canada using the same -- same excuses that -- that he needed the equipment to make direct broadcast to go against the CCP to expose the true intentions of CCP to the Western world. He used the same name as the money in Canada. He used the same reason and defrauded more than 170,000 out of one person. So that particular individual, Mr. Guo, lived in their house, drank their very expensive wine to a point that some -- you know, a person was vomiting blood. He used the excuse that he is supporting me, Guo Wengui, to disclose the -- to -- to expose the -- China's communist party and support the freedom and democracy in China. Those people believed him -- believed him with their life. So he used my name that he represent me to do all those things. When that particular individual learned about that he was -- go against me, he put out a threat to this family, stating that 703-780-9559 Misty Klapper & Associates Page 45 they were in the -- in the black society. He even asked the Canadian Royal Police to arrest that family member. So he used the same method by threatening people, by distorting people, by cheating people to -- to achieve his goal. He used the name of supporting me and he -- he -- so for that particular person he was not able to go back to mainland China and his entire wealth and estate were in jeopardy because of what he did. That's the fifth reason I'm suiing him. The purpose is to protect people like that individual. So I recommend to my attorney to seek this person to become a witness in court. So I recommend to you, you know, to have this person to appear in court as a witness. **Q What do you think that Baosheng Guo did with the money that you gave to him?** A I heard that she -- he bought a house. **Q Who did you hear that from?** A From the website. **Q Whose website?** A From Internet, from Internet.
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| 1
Q
Do you know what -- what page or -- or | MR. ALTMILLER: Right.
1 | | |
| what author? | THE WITNESS: -- from the social -- from | | |
| 2 | 2 | | |
| 3
A
Lots of them. They're in the documents | 3
the media, social media. From the social media. | | |
| that we provided. And that's the sixth reason I'm | BY MR. ALTMILLER: | | |
| 4 | 4 | | |
| suiing him. Through the law of the United States,
5 | Q
And who -- okay. So from social media,
5 | | |
| 6 | 6 | | |
| through the court of the United States, I hope the | who on social media said that he had used the money | | |
| judge can conduct an investigation exactly how much | 7 | | |
| 7 | to purchase a house? | | |
| money Mr. Guo Baosheng distorted.
8 | A
Our -- our colleagues who against CCP.
8 | | |
| There are people who are willing to | 9 | | |
| 9 | CHECK INTERPRETER: Maybe comrades. | | |
| appear in court as witness because he defrauded | 10 | | |
| 10 | THE WITNESS: My comrades. My comrades | | |
| \$2.08 million. This witness is willing to appear in | who are against CCP. There was -- I saw photo. | | |
| 11 | 11 | | |
| court. This person who owns a -- a roasting duck | 12 | | |
| 12 | Mr. Guo Wengui was in the photo with the gentleman, | | |
| store here, this person is willing to -- to be the | 13 | | |
| 13 | his attorney -- | | |
| witness to -- and he was one who recommended | CHECK INTERPRETER: Guo Baosheng. | | |
| 14 | 14 | | |
| attorneys here to represent him. He also said that | 15 | | |
| 15 | THE INTERPRETER: Guo Baosheng. | | |
| he will get \$3 million and split 50/50, 1.5 million | 16 | | |
| 16 | MR. MORRISSY: The Defendant. | | |
| each. | THE WITNESS: I saw a photo. Mr. Guo | | |
| 17 | 17 | | |
| So when they win this case, they will | 18 | | |
| 18 | Baosheng was in it with this gentleman right here, | | |
| receive \$3 million from me at which point they will | 19 | | |
| 19 | and Guo Baosheng said that he retained an attorney | | |
| split the 3 million 50/50. So the fifth reason I'm | and after that event our case was moved from one | | |
| 20 | 20 | | |
| suiing him is I'm hoping the court will just summon | 21 | | |
| 21 | court to a different court and the new court judge I | | |
| those witnesses that are talking about the owner of | 22 | | |
| 22 | heard this -- is a person who look down or | | |
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| this Beijing duck roast stores and have my attorney | 1 | | |
| 1 | discriminative against Chinese people. | | |
| to explain exactly where the money comes from and is | So -- and he also said that this new | | |
| 2 | 2 | | |
| going, how much money Mr. Guo Baosheng has spent to | 3 | | |
| 3 | attorney they hired look like certain president, so | | |
| buy his house and where did this \$2.08 million went | 4 | | |
| 4 | I'm asking you, are you the descendent of Mr. | | |
| and for -- in order to seek justice for those who | President Carter? | | |
| 5 | 5 | | |
| 6 | 6 | | |
| support the victims that was -- victimized by CCP. | MR. MORRISSY: First of all, can we just | | |
| 7
Q
You just testified that you had provided | 7
put your appearance on the record so we know who | | |
| reports that you had relied upon in concluding that | we're talking about here? | | |
| 8 | 8 | | |
| 9 | 9 | | |
| Baosheng Guo had used money from you to buy a house. | MR. LAUFER: We're talking about my | | |
| MR. MORRISSY: He didn't say anything | 10 | | |
| 10 | partner, James Eisenhower, who is related to the -- | | |
| about reports. | to former President Dwight Eisenhower. | | |
| 11 | 11 | | |
| 12 | 12 | | |
| MR. ALTMILLER: He said he provided -- he | MR. MORRISSY: Can we -- I'm sorry. Just | | |
| said he read it on the Internet and he said he | 13 | | |
| 13 | for the sake of identifying who was speaking -- | | |
| provided that to -- to -- to us. And we can read | MR. LAUFER: Yeah. My name is Alexander | | |
| 14 | 14 | | |
| 15 | 15 | | |
| back the answer. I just -- | Laufer, and I'm not related to any former presidents | | |
| MR. MORRISSY: Yeah, he said he read it | 16 | | |
| 16 | or politician of any kind. | | |
| on the -- the Internet. | MR. MORRISSY: And -- and you're also | | |
| 17 | 17 | | |
| 18 | 18 | | |
| MR. ALTMILLER: Yeah. And then he said | counsel for Defendant -- | | |
| that he had provided that information to us or to | 19 | | |
| 19 | MR. LAUFER: That is correct. | | |
| you. I shouldn't say to us. | MR. MORRISSY: -- just so -- | | |
| 20 | 20 | | |
| 21 | 21 | | |
| MR. MORRISSY: Okay. | MR. LAUFER: Yes. | | |
| THE WITNESS: I said from the Internet -- | 22 | | |
| 22 | MR. MORRISSY: That's all. | | |
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| 1 | MR. ALTMILLER: So we -- we should put | 1 | I mean -- | |
| 2 | that on the record. | 2 | MR. ALTMILLER: Okay. Okay. | |
| 3 | THE WITNESS: So after -- after Guo | 3 | MR. MORRISSY: Yeah, I mean, I think the | |
| 4 | Baosheng tweeted that information -- so after Mr. | 4 | testimony was that it was on the Internet and posted | |
| 5 | Guo Baosheng tweeted the certain information, indeed | 5 | by non-parties and he saw it. | |
| 6 | our case was moved from one of the state court to | 6 | MR. ALTMILLER: Okay. | |
| 7 | another and the -- and after what you said, this -- | 7 | MR. MORRISSY: I think that was the | |
| 8 | this proved that Mr. Guo Baosheng did hire a | 8 | substance of his testimony. | |
| 9 | descendent of a certain president to represent him. | 9 | BY MR. ALTMILLER: | |
| 10 | Now, that -- he said that it's a threat | 10 | Q
And does that constitute your -- or is | |
| 11 | to us because he also state -- stated that the new | 11 | that the basis for your belief that he used your | |
| 12 | judge is discriminatory against Chinese people. So | 12 | money to buy a house? | |
| 13 | based on what he said, that represent that Mr. Guo | 13 | A
That's -- that's not it. Not only he | |
| 14 | Baosheng is not respectful of the U.S. laws and, | 14 | used that money to purchase a house, but he is a | |
| 15 | therefore, we need to -- to bring the truth out. We | 15 | person without any ethics. He's using this logan of | |
| 16 | need to seek justice and give equitable result to | 16 | defending democracy to defraud people. He defrauded | |
| 17 | the comrades that support us who against CCP. | 17 | most of the people that -- that are against the | |
| 18 | I highly urge my attorney and the other | 18 | communist party. | |
| 19 | attorneys that -- take a good look of the Twitter | 19 | Secondly, he wrote a book. And the -- | |
| 20 | that Guo Baosheng tweeted because that kind of | 20 | the name of the book is called The Professional. So | |
| 21 | language create a great pressure to all of us and | 21 | using the -- the pseudonym Manda, M-A-N-D-A, he said | |
| 22 | create pressure to those who support us to go | 22 | that the book, Professional, has sold for -- 800 | |
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| 1 | against -- those who go against communist party. | 1 | million copies and he -- it -- and it was on top 10 | |
| 2 | Just think about it; why is -- he stressed the new | 2 | most read -- or top 10 sale list in the United | |
| 3 | attorney he hire is a white person. What's the | 3 | States. A lot of students fell for it and purchased | |
| 4 | difference between a white attorney versus colored | 4 | his book. | |
| 5 | attorney? He made such a tweet even before the case | 5 | He claim himself as a teacher and a | |
| 6 | was moved to a different court. | 6 | scholar so a lot of students in Germany and China | |
| 7 | BY MR. ALTMILLER: | 7 | fell into his trap. | |
| 8 | Q
Okay. I -- I might have been less than | 8 | Additionally, other than purchasing the | |
| 9 | clear in my question. I wasn't asking about that. | 9 | house, he claim himself -- he claim that he is a -- | |
| 10 | So what I was asking about is you had said that | 10 | he's a pastor. He traveled to places explaining the | |
| 11 | he -- you had heard that he had used money from you | 11 | Bible, representing God and, however, he went to | |
| 12 | to buy a house. And I'm asking from whom did you | 12 | Japan, Tokyo by using my name. He visited a strip | |
| 13 | hear that. I'm looking for the names of the people | 13 | club. | |
| 14 | who posted on social media who told you that. | 14 | So what I'm saying to you is that he used | |
| 15 | A
A lot of them floating around in social | 15 | the name of the book to -- to defraud students. He | |
| 16 | media. If that information is not enclosed in the | 16 | used the name of against -- against the CCP to | |
| 17 | material that I submitted, I can go back and look it | 17 | defraud those who are democratically clean people | |
| 18 | up, if -- if I didn't submit it. | 18 | and that is the seventh reason I'm suiing him. | |
| 19
20 | Q
Okay. I don't remember seeing that, but
I will -- | 19 | CHECK INTERPRETER: And also the witness
said that he used the name of being pastor and then | |
| 21 | MR. MORRISSY: Well, it wasn't anything | 20
21 | cheating God. | |
| 22 | that was even close to asked for in your demands, so | 22 | THE INTERPRETER: He used the name as | |
| | Misty Klapper & Associates | | Misty Klapper & Associates | |
| | 703-780-9559 | | 703-780-9559 | |
Case 22-50073 Doc 404-30 Filed 05/20/22 Entered 05/20/22 11:52:18 Page 16 of
703-780-9559 Misty Klapper & Associates Page 54 pastor, cheating God. MR. MORRISSY: Can -- can we take a five-minute break? MR. ALTMILLER: Sure. MR. MORRISSY: Go off the record for a moment. MR. ALTMILLER: Sounds good. Okay. VIDEO OPERATOR: We're going off the record at 11:48, 11:48. (Thereupon, a recess was taken.) VIDEO OPERATOR: We're back on the record at 11:59. BY MR. ALTMILLER: **Q Is there any reason other than the social media that you read that you believe that Baosheng Guo purchased a house with -- with money he received from you?** A Yes. Yes, there are other reasons. You know, he used the name as a pastor to -- went to Japan and went to a strip club. He went to Taiwan, visited a lot of officials. He went to Japan and 703-780-9559 Misty Klapper & Associates Page 55 met with Mr. Li Xioa Mu. And all those things that he did has nothing to do with -- exposed the -- the communist parties or support our revolution, nothing with that. So he went to different places, collect all -- a whole bunch of money and he was very poor originally, so for all those money that he collected he was able to buy a house. **Q And the reason you believe that, is that only from what you read in social media? Is there any other reason that you believe that he bought a house with these proceeds that he received?** A Because we're -- during a -- phone conversations, he many times would iterate that he was very poor and that he went all over the place to -- soliciting our comrades for money, including the person in Canada that I mentioned, Robert Wang. CHECK INTERPRETER: The Check Interpreter thinks that the witness actually say over the telephone conversation Guo Baosheng claimed that he was very poor, so he would not have the money to buy the house. And he went all over the place to 703-780-9559 Misty Klapper & Associates Page 56 solicit money, including to Canada and from Robert Wang. So I believe that the money that he solicited he used to purchase the house. THE WITNESS: That's it. BY MR. ALTMILLER: **Q So where did he purchase the house?** A I think somewhere in Virginia. **Q Okay. Now, you said that there were other witnesses that you hope would testify with regard to fraud that was committed by Baosheng Guo. What are the names of those witnesses?** A All those peoples are on the watchlist of the CCP, so their life is in danger in the event those information were disclosed. So I would like -- I will -- I cannot tell you at this point. However, if we go through the court procedures to assure their safety and to protect their identities, then we can -- we can talk about the witnesses. Otherwise, I don't want those information to be used by you attorneys or by Mr. Guo Baosheng to hand it over to the CCP. Just like after he had a round of the 703-780-9559 Misty Klapper & Associates Page 57 drinking with you guys, then he posted a photo of you all, claiming that his attorney is a descendent of certain president. So I don't want the same thing to happen for him to accidentally disclose those information. **Q All right. The -- the -- well, let me ask you this: Did Baosheng Guo represent to you that he needed \$2,000 for traveling expenses in relation to this group whose goal it was to assist victims of the CCP?** MR. MORRISSY: Sorry. Just to be clear. I'm not sure if this is a difference without a distinction, but was it to assist victims or was it anti-CCP? MR. ALTMILLER: So here's -- I can -- I'm only going by the allegations in the complaint. MR. MORRISSY: Okay. MR. ALTMILLER: The allegations in the complaint state that there was a group whose goal it was to assist victims of the CCP. This is referred to in caps, Chinese Support Group, the Chinese Support Group. The allegation in the complaint that
703-780-9559 Misty Klapper & Associates Page 58 I'm reading directly from is that Baosheng Guo represented to Plaintiff that Defendant needed \$2,000 for traveling expenses pertaining to the Chinese Support Group. Since that's a defined term, I'm actually defining it in -- every time I ask that question so that the question is clear. MR. MORRISSY: Okay. Good. Thank you. THE WITNESS: Yes. BY MR. ALTMILLER: **Q Do you believe that Baosheng Guo received a lot of money from the Chinese government in order to say critical things about you?** A Yes. **Q Okay. With regard to what we just discussed with the \$2,000 for traveling expenses, did you give him that \$2,000?** A Yes. **Q And when he represented to you that he needed it for traveling expenses, how did he make that representation to you? Was it verbal or was it in writing?** 703-780-9559 Misty Klapper & Associates Page 59 A Verbal. **Q And you have alleged that Baosheng Guo represented to you that he needed \$10,000 to arrange a support conference for you in Washington; is that true?** A Yes. MR. MORRISSY: Didn't we go over this previously? MR. ALTMILLER: No. I'm just -- I'm -- no, I haven't -- I haven't asked that question. That's a different one. It's a different allegation and it's a different -- presumably, it's a different time frame. MR. MORRISSY: Okay. Sorry. Thank you. BY MR. ALTMILLER: **Q Is -- is that true?** A Correct, yes. **Q And was that representation also made verbally to you?** A Yes. **Q And did you give him \$10,000 or any money in response to that representation?** 703-780-9559 Misty Klapper & Associates Page 60 A Yeah, I gave him 10,000. Once again, it's not that I gave it to him. He defrauded me instead. **Q I understand. When I use the word give, I don't want to be -- transferred is probably a better word. And -- and he also represented to you that he could provide important details on corrupted Chinese government officials in exchange for \$10,000; is that correct?** A Ten thousand, yes. **Q And did you give him that 10 -- excuse me -- did you transfer that \$10,000 to him?** A Yes. **Q Okay. And did he make that representation verbally or did he make it in writing?** A Verbal. **Q Okay. You have alleged that Baosheng Guo tweeted the following: Guo states that he was sentenced to prison during the students' movement in 1989 for providing fund to the students, but he was actually charged with false pretenses, so he was** 703-780-9559 Misty Klapper & Associates Page 61 **obviously lying. Did Baosheng Guo quote -- tweet that?** A I don't remember. **Q That statement, was that -- is -- is that statement false? And -- and let me rephrase it. The statement that I just said that you alleged that Baosheng Guo had tweeted; is that statement false?** MR. MORRISSY: Can you just turn it around and -- MR. ALTMILLER: Let's do that. You know, I'm actually -- actually, I already regret the question, so I'm going to -- I'm going to -- will just withdraw it and then I'm going to ask it in a much more specific way. BY MR. ALTMILLER: **Q Is it -- is it true that you stated that you were sentenced to prison during the students' movement in 1989 for providing funds to students?** MR. ALTMILLER: And I want to be clear when I ask him this. I'm asking is it true that he stated it. I'm not asking is it true that it happened. I'm asking whether or not he's ever
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| Page 62 | Page 64 |
|-----------------------------------------------------|----------------------------------------------------------|
| 1 | THE INTERPRETER: Hackers to frame |
| stated that. | 1 |
| THE WITNESS: I don't remember. | Chinese activists? |
| 2 | 2 |
| 3 | 3 |
| BY MR. ALTMILLER: | MR. ALTMILLER: Human rights activists. |
| 4
Q
And were you ever sentenced to prison in | THE INTERPRETER: Human rights activists.
4 |
| China? | THE WITNESS: That's incorrect. |
| 5 | 5 |
| 6
A
Yes. | 6
MR. ALTMILLER: Okay. And I want to be |
| 7
Q
And what was it for? | clear that I was asking him whether or not it was
7 |
| A
Anti-revolution -- incite -- incite
8 | tweeted, not whether or not the statement was true,
8 |
| 9 | 9 |
| revolution. | but whether or not Baosheng had tweeted that. |
| 10
Q
Inciting revolution? | MR. MORRISSY: I mean, has admitted these
10 |
| A
Inciting.
11 | statements, so --
11 |
| 12 | 12 |
| CHECK INTERPRETER: Inciting | MR. ALTMILLER: All right. Let's -- |
| 13 | 13 |
| anti-revolution. | I'm -- I'm trying to get foundation because I get |
| THE INTERPRETER: Inciting | into a problem when I ask about -- |
| 14 | 14 |
| 15 | 15 |
| anti-revolution. | BY MR. ALTMILLER: |
| 16
BY MR. ALTMILLER: | 16
Q
You know what, I'm happy to jump in and |
| 17
Q
And how long were you in prison? | ask it this way: Have you ever been suspected of
17 |
| 18
A
Twenty-two months. | 18
collaborating with hackers to frame Chinese human |
| 19
Q
And how old were you? | 19
rights activists by anybody? Have you ever been |
| A
Nineteen years old.
20 | suspected by anybody of -- of doing that?
20 |
| 21
Q
Okay. All right. Do -- you have alleged | 21
MR. MORRISSY: How would he know? |
| 22 | 22 |
| that Baosheng Guo tweeted in English that you are | MR. ALTMILLER: I'm okay if the answer is |
| Misty Klapper & Associates | Misty Klapper & Associates |
| | |
| 703-780-9559 | 703-780-9559 |
| Page 63 | Page 65 |
| 1 | 1 |
| suspected of collaborating with hackers to frame | I don't know. |
| Chinese human rights activists. Is that correct | MR. MORRISSY: Yeah. No. It calls for |
| 2 | 2 |
| that Baosheng Guo has tweeted that? | speculation. |
| 3 | 3 |
| 4 | 4 |
| MR. MORRISSY: Are we just going to go | THE WITNESS: Never. Those were the |
| down the complaint and ask if -- ask if the | sayings by the communist party. |
| 5 | 5 |
| allegations in the complaint are true? | MR. ALTMILLER: I'm happy to accept your |
| 6 | 6 |
| 7 | 7 |
| MR. ALTMILLER: Not really, but we're | answer, by the way. If -- if we want to establish |
| going down the -- the really important ones because | that the witness' answer to whether or not this |
| 8 | 8 |
| we can skip the first 100. So, actually, it leaves | statement is true is I don't know, I'm -- I'm very |
| 9 | 9 |
| 10 | 10 |
| very few when you get out of the legal conclusions. | happy with that answer. |
| | |
| I'm actually pretty much almost finished asking | MR. MORRISSY: I'm -- I'm not sure that's |
| 11 | 11 |
| issues in here. | what his answer was. |
| 12 | 12 |
| 13 | 13 |
| MR. MORRISSY: Okay. | MR. ALTMILLER: Well, you told me he |
| MR. ALTMILLER: I just need to -- I need | couldn't know, so I'm -- |
| 14 | 14 |
| to know what -- I just need to know answers to some | MR. MORRISSY: No. I told you it calls |
| 15 | 15 |
| 16 | 16 |
| of these. | for speculation. |
| BY MR. ALTMILLER: | MR. ALTMILLER: Okay. |
| 17 | 17 |
| Q
So let me just first ask, did -- did --
18 | MR. MORRISSY: I said, how is he supposed
18 |
| 19 | 19 |
| do you -- is it true that Baosheng Guo has tweeted | to know. |
| 20 | THE WITNESS: So the questions you ask |
| that? I'm sorry. And I'll say tweeted that Wengui | 20 |
| Guo is suspected of collaborating with hackers to | were the rumors spread by the CCP on the web. |
| 21 | 21 |
| 22
frame Chinese human rights activists. | 22 |
| | |
| Misty Klapper & Associates | Misty Klapper & Associates |
| 703-780-9559 | 703-780-9559 |
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| | 32 | | |
|--------|------------------------------------------------------------------------------------------------------------|--------|-----------------------------------------------------------------------------------------------------|
| | Page 66 | | Page 68 |
| 1 | BY MR. ALTMILLER: | 1 | incurred as a result of this defamation that you |
| 2 | Q
Okay. So the CCP spread -- spread rumors | 2 | allege Mr. Baosheng committed? |
| 3 | on the web that you were suspected of collaborating | 3 | A
Yes. |
| 4 | with hackers to frame Chinese human rights | 4 | Q
And with regard to the assets in -- that |
| 5 | activists; is that correct? | 5 | you have in China, what assets are being damaged in |
| 6 | A
Correct. | 6 | China? |
| 7 | Q
Okay. All right. | 7 | A
Golden Spring, Beijing and Zenith, |
| 8 | A
That question is -- really helped CCP. | 8 | Z-E-N-I-T-H, and Pangu Investment, Fountain |
| 9 | Q
Now, you have alleged that you've | 9 | Security. |
| 10 | suffered damages as a result of these statements by | 10 | MR. PODHASKIE: Founders. |
| 11 | Baosheng Guo; is that correct? | 11 | THE WITNESS: Founders Security. |
| 12 | A
Grave damage, yes. | 12 | MR. MORRISSY: Founders. |
| 13 | Q
And can you, please, describe what that | 13 | THE INTERPRETER: Oh, Founders Security. |
| 14 | damage is that you suffered as a result of these | 14 | BY MR. ALTMILLER: |
| 15 | statements by Baosheng Guo? | 15 | Q
Are all -- are these companies? |
| 16 | A
What he said caused great hurt and damage | 16 | A
Yes. |
| 17 | to my family members in China. After his rumor and | 17 | Q
And do you own these companies? |
| 18 | after he said things against me, my family members | 18 | A
No. My family. |
| 19 | and my assets in China suffered a great deal. After | 19 | Q
Okay. And the employees that you |
| 20 | my family members saw the video that he posted, they | 20 | discussed, are they employees of these companies |
| 21 | weren't able to go to sleep. They have to -- using | 21 | that you've listed? |
| 22 | a sleeping aid or sleeping pills. | 22 | A
Yes. |
| | Misty Klapper & Associates | | Misty Klapper & Associates |
| | 703-780-9559 | | 703-780-9559 |
| | | | |
| | | | |
| | Page 67 | | Page 69 |
| 1 | So -- so the court in Dalian after | 1 | Q
Okay. Okay. And -- and were you fined |
| 2 | the case -- so the court in Dalian -- | 2 | 13 -- was it \$13 billion or -- |
| 3 | CHECK INTERPRETER: D-A-L-I-A-N. | 3 | A
870 billion -- okay. 8.7 billion cash; |
| 4 | THE WITNESS: Dalian. After the -- after | 4 | 4.0 billion shares, total of 13 billion, around. |
| 5 | the case of that person that we talked about before | 5 | Q
And was that a fine to the companies or |
| 6 | and they fined me \$13 billion and after that -- so | 6 | to somebody personally? |
| 7 | he -- they used Guo Baosheng's videotapes as | 7 | A
The company. |
| 8
9 | evidence in the court and using that to threaten my
family, caused a grave danger to my family's safety | 8
9 | Q
Okay. All right. Do you -- do you have
any documents related to the actions that were taken |
| 10 | as well as my employees' safety, claiming that I was | 10 | in China that you've just described? |
| 11 | doing bad things overseas and they used Guo | 11 | A
Yes. |
| 12 | Baosheng's videos and Twitter as evidence in court. | 12 | Q
Have they been produced to your attorney? |
| 13 | And that's the eighth reason I must sue | 13 | A
I will do that. We will do that. I |
| 14 | Guo Baosheng for him to stop further hurting my | 14 | don't believe you asked for it. |
| 15 | family members, my employees, my comrades as well as | 15 | Q
Okay. The -- the companies; Golden |
| 16 | my assets. | 16 | Spring and Zenith and Pangu and Founders Security, |
| 17 | So I'm pleading to my attorney and you as | 17 | those are companies that are not owned by you, but |
| 18 | well to increase the damage that -- or the dollar | 18 | they're owned by your family, correct? |
| 19 | amount that Mr. Guo Baosheng should pay. | 19 | MR. MORRISSY: Just to clarify, what does |
| 20 | BY MR. ALTMILLER: | 20 | that mean, owned by? We need to clarify what that |
| 21 | Q
And are -- those damages that you just | 21 | means. I know he said it, but -- |
| 22 | described, are those all the damages that you have | 22 | MR. ALTMILLER: Yeah, so I'm trying to |
| | Misty Klapper & Associates
703-780-9559 | | Misty Klapper & Associates
703-780-9559 |
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703-780-9559 Misty Klapper & Associates Page 70 clarify. I mean, I'm -- MR. MORRISSY: Well, no. It doesn't seem like it from your question. You're just glossing over what owned by his family means, right? MR. ALTMILLER: Not by him. How is that? Owned by people that are not Wengui Guo. MR. MORRISSY: I'm not sure that's what he means. MR. ALTMILLER: Okay. Well, then that's what I'm trying to find out. That's why I clarified it by saying owned by his family and not by him. I didn't just say owned by his family. I said owned by his family and not by him. THE WITNESS: No, no, you're wrong. MR. PODHASKIE: You want to go off the record? I can explain. MR. ALTMILLER: I don't mind. I'll go off the record to -- I mean, I just want to know. MR. MORRISSY: Okay. Yeah. No. I hear you, and I'm -- I'm just trying to let you know -- MR. ALTMILLER: All right. Let's -- MR. MORRISSY: -- that you're going down 703-780-9559 Misty Klapper & Associates Page 71 a path that is sort of incorrect. MR. ALTMILLER: Okay. MR. MORRISSY: I think it might be a product of translation and -- MR. ALTMILLER: Okay. MR. MORRISSY: Not that there's anything wrong with the translation. Just -- MR. ALTMILLER: Let's -- let's just go off and I'm happy to clarify. I'm -- I'm not trying to create a misimpression. VIDEO OPERATOR: We're going off the record at 12:26. (Thereupon, a discussion was had off the record.) VIDEO OPERATOR: We're back on the record at 12:29. MR. ALTMILLER: All right. Now, we have stipulated that the companies that were described are owned by a fund, which is in turn owned by the family of the deponent, Wengui Guo. Right. Okay. I'm sorry. MR. LAUFER: Well, we're stipulating to 703-780-9559 Misty Klapper & Associates Page 72 the testimony. We don't know that it's true. MR. MORRISSY: Right, yeah. Yeah, we're stipulating that the testimony of the deponent is that his family of which he is a part -- MR. ALTMILLER: Right. MR. MORRISSY: -- is a beneficiary of a fund, for lack of a better word or understanding, that owns and controls certain entities. MR. ALTMILLER: Right. Okay. BY MR. ALTMILLER: **Q So now let me ask this then: What is your percentage ownership of that fund that owns the companies?** A We are listed as beneficiaries. We do not designate percentages. **Q Okay. Okay. And you believe that the actions that were taken against these companies were taken specifically because of statements that were made by Baosheng Guo on his Twitter feed, correct?** A Yes. **Q Okay. And is there a reason why you believe that the government took that action in** 703-780-9559 Misty Klapper & Associates Page 73 **response to the tweets by Baosheng Guo?** A No. MR. ALTMILLER: I'm going to tell you what, let's do this -- I actually have really just two primary topics to go over next, and the next one I have is pretty big and I was planning on taking a break around 12:45 anyway to break for lunch and Alex needs to feed the meter. So I'm actually pretty hopeful that we can -- we don't have that much longer; I mean, you know, maybe an hour or two on this stuff. So if that's good -- MR. MORRISSY: How long do -- so do you want to break now? THE WITNESS: Continue is okay. I don't want to stop; continue. MR. MORRISSY: If we have an hour, why break? MR. ALTMILLER: Well, it might be -- it might go to two. I'll tell you what, let's go -- let's -- let's go and see where -- let's see where it takes us.
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703-780-9559 Misty Klapper & Associates Page 74 MR. MORRISSY: If we need to break to feed meters, that's one thing, obviously, but -- MR. LAUFER: Yeah, that's fine with me. I'll run down and -- MR. MORRISSY: Okay. But if -- MR. LAUFER: That's fine. MR. MORRISSY: But, yeah, I mean, if we're an hour or two off, let's just power through. I mean, the deponent doesn't mind, as long as you don't mind. Oh, of course, and you too. MR. ALTMILLER: Well, I mean, I'm just -- I'm just thinking about it. I don't want to -- I don't want to stress people out too much and -- and at some point I do need to get fed and I -- I don't want to get, you know, hangry. But let's -- let's do this: Let's -- let's keep rolling and let's see where it takes us. MR. MORRISSY: And by all means, if the Interpreter or the Court Reporter needs to break, please let us know. MR. ALTMILLER: And I'm -- I'm going to want to break in, you know, an hour anyway, but -- 703-780-9559 Misty Klapper & Associates Page 75 but let's -- let's see where -- let's see where we go. BY MR. ALTMILLER: **Q All right. Do you have a -- a website called guo -- www.guo.media? Is that your website?** A No. MR. ALTMILLER: Let's -- let's mark this as an exhibit. (Whereupon, Deposition Exhibit Number 1 was marked for Identification.) BY MR. ALTMILLER: **Q What I've handed you is a -- a printout, and I'm not as concerned right now with the English translation that's below it, but really with just the screenshots that are -- are there and I wanted to just see what -- if you recognized any of these postings that are in Chinese and -- and if you made those postings.** MR. MORRISSY: So just to be clear, the document that's been marked as an exhibit says on the top: 3 -- 703-780-9559 Misty Klapper & Associates Page 76 MR. ALTMILLER: Yes. MR. MORRISSY: -- Twitter in www.guo.media? MR. ALTMILLER: Yes. MR. MORRISSY: What -- what does that mean? MR. ALTMILLER: It means absolutely nothing for the purposes of the exhibit. And I think we can stipulate that it is not -- MR. MORRISSY: Okay. MR. ALTMILLER: -- part of the exhibit. In fact, the only thing I'm asking the -- the deponent about is -- are -- are the screenshots. We can get to other parts of this later, but I want to simply identify the screenshots and if -- if he recognizes those at all. MR. MORRISSY: Okay. THE WITNESS: Yes. BY MR. ALTMILLER: **Q And where were these posted or how were they posted?** THE INTERPRETER: Where or how? 703-780-9559 Misty Klapper & Associates Page 77 MR. ALTMILLER: Yes. THE WITNESS: Guo Media. BY MR. ALTMILLER: **Q And what is Guo Media?** A It's a social media platform similar to that of Twitter. I am one of the user -- one of the users. **Q Did you create this platform?** A I did not create it. I'm one of the participants. I'm just a consultant. That's all. **Q Who is the Guo in Guo Media?** A This Guo related to the disclosure of informations. So it is kind of a strategic decision that is used to disclose -- disclose information. **Q Is -- is -- does the Guo in Guo.media refer to any person?** A No. It just means disclosure of informations for revolution. **Q And were you at all involved in the creation of this platform?** A I did not participate. I just suggested. MR. ALTMILLER: Just what?
703-780-9559 Misty Klapper & Associates Page 78 THE INTERPRETER: Suggested. MR. ALTMILLER: Suggested. CHECK INTERPRETER: The Check -- the Check Interpreter thinks it might be better to use made recommendations. I did not participate. I merely made recommendations instead of use the word suggested. MR. ALTMILLER: Okay. That's -- that's fine. THE INTERPRETER: I made a recommendation. That's fine. BY MR. ALTMILLER: **Q To whom did you make recommendations with regard to Guo Media?** A Investment company of Guo Media. **Q Did they come to you for advice or recommendations?** A Yes. **Q Do you have any ownership interest in the -- in Guo Media or in the company that owns Guo Media?** A No. 703-780-9559 Misty Klapper & Associates Page 79 **Q Are you featured in any way prominently on www.guo.media?** MR. MORRISSY: Please clarify what you mean by prominently. Maybe he will. THE WITNESS: The wording you're using is very similar to that of the communist party. What do you mean by featured or prominent? BY MR. ALTMILLER: **Q Okay. Well, I don't -- I don't want to use the language of a communist government. Is your picture found on the website www.guo.media?** A Sure. A lot of people's photos were up there, not -- not just me. **Q Okay.** A It is just a place that you transfer or transmit informations and photos, not just my photos. **Q So if you go to Guo Media, on the very first page, does it have your picture?** A The first page -- the first page does not have my photos. It has many other photos. **Q Okay. Let me -- let me -- let me ask you** 703-780-9559 Misty Klapper & Associates Page 80 **about the -- well, you know what, I'm going -- I'm going to do this with the -- let's look at this.** MR. ALTMILLER: Let's mark this as Number 2. (Whereupon, Deposition Exhibit Number 2 was marked for Identification.) BY MR. ALTMILLER: **Q Do you recognize this document?** A I recognize it. **Q Did you make these posts?** MR. MORRISSY: I'm sorry. Which document are we looking at? MR. ALTMILLER: Number 2. Sorry. Number 2. Fair enough. MR. MORRISSY: Because he had that behind Number 1. So do that one. Sorry. THE WITNESS: Yes, it's part -- it's just part of it. The source was Guo Baosheng. I re-tweeted it. BY MR. ALTMILLER: **Q So he had tweeted his driver's license** 703-780-9559 Misty Klapper & Associates Page 81 **and passport and you re-tweeted it?** A The document that he re-tweeted included those documents and I re-tweeted it. **Q Okay. So you got those documents from a tweet from Baosheng Guo?** A Yes. **Q Okay. Okay.** MR. MORRISSY: Got what documents? MR. ALTMILLER: The passport and driver's license. MR. MORRISSY: But that's not -- I don't think that's exactly what he said. I think the testimony was that these things were part of a document that he re-tweeted. MR. ALTMILLER: Right. In other words, I understood his testimony to be that he never had those documents, that he got them because somebody probably -- I assume my client -- tweeted them. MR. MORRISSY: Yeah. I'm only -- MR. ALTMILLER: Tweeted a document that had that in there. MR. MORRISSY: Yeah. It was what he
703-780-9559 Misty Klapper & Associates Page 82 filed with the court. I mean, it's no secret. He filed this picture with the court and then he tweeted it. MR. ALTMILLER: Wait. He filed -- MR. MORRISSY: He filed this photograph and this photograph with the court. MR. ALTMILLER: Okay. MR. MORRISSY: It's a -- it's a public filing. And then he sent out a tweet about it. You don't know that? Yeah. It's in the court file. MR. ALTMILLER: Okay. I got you. MR. PODHASKIE: It's part of the notice of removal. MR. ALTMILLER: Oh. MR. MORRISSY: Or some letter that preceded the -- the notice of removal. MR. ALTMILLER: So it's part -- it's part of the notice of removal? Okay. That's why I ask -- that's why I ask questions in discovery. MR. MORRISSY: Yeah. No. I just want to make sure that it -- yeah, it was -- I mean, the document that was filed with the court -- 703-780-9559 Misty Klapper & Associates Page 83 MR. ALTMILLER: Right. MR. MORRISSY: -- by your client -- MR. ALTMILLER: Right. MR. MORRISSY: -- was given back to you in discovery, so it should be pretty clear that that's what happened. MR. ALTMILLER: Okay. MR. MORRISSY: I mean, I -- I gave you that document back. MR. ALTMILLER: I understand. Well, that's why I said that's why -- that's why I ask questions, that's why I ask Interrogatories so people can say, hey, this is what happened and I go, okay, I don't have to ask that question. MR. MORRISSY: Yeah. No. That happened and -- but you asked the question. MR. ALTMILLER: Let's do this, actually. All right. Let's mark this as 3. (Whereupon, Deposition Exhibit Number 3 was marked for Identification.) 703-780-9559 Misty Klapper & Associates Page 84 BY MR. ALTMILLER: **Q Now, what -- what I've handed to you is a certificate of translation that relates to some of the postings that we just looked at in Exhibit 1. I'm now referring to Exhibit 3 being the translation. This has been previously provided to your counsel. Let me ask, have you seen this document before?** A I've seen it. **Q And -- and, actually, let me -- let me revise what I -- what I just said about that. Let me revise because I said something that was -- that was inaccurate. I was referring to the posts on -- on -- on Guo Media. These are actually translations of -- of videos. And --** A I understand. I have seen it. MR. MORRISSY: Is this what was given yesterday? MR. ALTMILLER: No, no. I -- this was -- was given yesterday, but it was given weeks before. I mean, I -- 703-780-9559 Misty Klapper & Associates Page 85 MR. MORRISSY: But in a different form? MR. ALTMILLER: Yeah. We just -- I -- I delivered this in -- pursuant to the Rule 26 disclosures in our continuing duty to supplement the -- those -- those disclosures. MR. MORRISSY: Okay. Yeah. I just actually don't have it in front of me right now. MR. ALTMILLER: The -- MR. MORRISSY: You gave it to me. MR. ALTMILLER: Yeah. MR. MORRISSY: I just didn't have it in front of me when I asked the question. MR. ALTMILLER: Oh, okay. MR. MORRISSY: I'm -- I just asked for the clarification. That's all. MR. ALTMILLER: Oh, okay. Okay. BY MR. ALTMILLER: **Q So you've seen this before. Do -- have you looked to see whether or not you think this accurately reflects the statements that were made in the videos that are identified?** A Yes, yes.
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| 1 | Q
And I want to talk about just a couple | 1 | A | Yvette Wong. |
| 2 | of -- a couple of aspects of this, if I could. Did | 2 | Q | And who -- who is Yvette Wang? |
| 3 | you refer to Baosheng Guo as a political liar, a | 3 | A | Was my former employee. Currently my |
| 4 | religious liar and a beast? | 4 | | partner, a person who supports disclosure of |
| 5 | A
Yes, I did. | 5 | | information, support the revolution. Also was hurt |
| 6 | Q
And -- and that's because you believe | 6 | by the CCP. | |
| 7 | that Baosheng Guo is a liar, correct? | 7 | Q | Jacki Wang, is it -- Wang? |
| 8 | A
Yes. | 8 | A | One of the comrade in California who |
| 9 | Q
And you have also said that he has | 9 | | opposed communist party. |
| 10 | attempted to swindle money and defraud donations; is | 10 | Q | And he -- he was defrauded by Baosheng |
| 11 | that correct? | 11 | Guo? | |
| 12 | A
Yes. | 12 | A | Yes. |
| 13 | Q
And you believe that to be true as well? | 13 | Q | How much was he defrauded out of? |
| 14 | A
Correct. | 14 | A | He will not disclose the amount of money |
| 15 | Q
And we've discussed the -- the reason you | 15 | | that he was defrauded because he was one of the |
| 16 | believe that, I think, previously. And is that | 16 | | witness, was also the person who purchased or paid |
| 17 | because you believe that he defrauded you? Correct? | 17 | | for the airline tickets and expenses. And the name |
| 18 | A
Yes. | 18 | | is G.S. Muyang, GS M-U-Y-A-N-G. |
| 19 | Q
And you believe that he did that to other | 19 | Q | Okay. And Robert Wang, who is that? |
| 20 | human rights activists as well, correct? | 20 | A | Canadian person that was defrauded about |
| 21 | A
Yes. | 21 | | 180,000 to 160,000 by him. |
| 22 | Q
And is -- the reason that you believe | 22 | Q | Okay. And do you know how he was |
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| 1 | that's the case is because of the frauds that you | 1 | | defrauded by Baosheng Guo? |
| 2 | described earlier in your testimony against other | 2 | A | He used that he was supporting Guo |
| 3 | human rights activists? | 3 | | Wengui, and he needed the money to host a conference |
| 4 | A
Yes. | 4 | | and for travel expenses, et cetera. |
| 5 | Q
And those are the -- the folks that you | 5 | Q | And you know this because Robert Wang |
| 6 | can't give me their names because of the peril that | 6 | told you that? | |
| 7 | it would put them in with the Chinese government, | 7 | A | Yes. |
| 8 | correct? | 8 | Q | Okay. All right. Wayne -- what is it? |
| 9 | A
Some of them I already disclosed in the | 9 | | THE INTERPRETER: Cao. |
| 10 | document that I submitted. Some of them I cannot | 10 | | BY MR. ALTMILLER: |
| 11 | disclose. | 11 | Q | -- Cao was also defrauded by Baosheng |
| 12 | Q
The ones that you did disclose, can you | 12 | | Guo; is that correct? |
| 13 | give me their names? | 13 | A | The money he defrauded from me he gave it |
| 14 | A
One person's name is Mu Yung. The other | 14 | to Wayne Cao. | |
| 15 | one is Jacki Wang, Sara and Robert Wang. I provided | 15 | | CHECK INTERPRETER: Wayne Cao gave the |
| 16 | those names. Wayne Cao and Hank, Yvette Wang. | 16 | money to him. | |
| 17 | MR. MORRISSY: Yvette. | 17 | | THE INTERPRETER: Oh, Wayne Cao gave the |
| 18 | THE INTERPRETER: Yvette Wang. | 18 | money to -- | |
| 19 | CHECK INTERPRETER: Yvette. | 19 | | CHECK INTERPRETER: The money that he |
| 20 | MR. MORRISSY: Yvette. | 20 | | defrauded from him, it was Wayne Cao who hand the |
| 21 | BY MR. ALTMILLER: | 21 | money to him. | |
| 22 | Q
Y-V-E-T-T-E? | 22 | | THE WITNESS: Wayne Cao was the person |
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703-780-9559 Misty Klapper & Associates Page 90 who gave the money to Guo Baosheng. BY MR. ALTMILLER: **Q Oh, so that's somebody who gave it to -- to him on your behalf? Okay.** A I gave the money to Wayne Cao. Wayne Cao gave the money to Guo Baosheng. **Q Okay. How much money?** A Over \$10,000 of cash and plus some wine and liquor, total about approximately 20,000. **Q Okay. I actually -- I meant to ask you, with regard to Exhibit 2, which was the driver's license and passport, is there a reason that you posted that on Guo Media?** MR. MORRISSY: Well, did he post it? That what -- that was never said in the testimony. MR. ALTMILLER: Okay. Well, I'll ask him. MR. MORRISSY: Yeah, let's clear that -- MR. ALTMILLER: He said he re-tweeted it, so -- MR. MORRISSY: Well, no, he didn't. He said that -- that's not what he said. 703-780-9559 Misty Klapper & Associates Page 91 MR. ALTMILLER: Okay. I will ask him -- I will ask him then what he said. MR. MORRISSY: Okay. BY MR. ALTMILLER: **Q Did -- is this you posting the driver's license and passport of Baosheng Guo?** A No. Guo Baosheng, he, himself, tweeted that amongst his legal documents in court. I re-tweeted it. **Q Okay. That's what I thought you said. And I'm asking why you re-tweeted it?** A He tweeted it. I'm just helping him so that people know the progress of the case. **Q So you're doing it to help Baosheng Guo?** A I'm helping people to understand the progress of this case since he was the one who tweeted it, I re-tweeted it, because all those who were cheated by him were paying attention on the progress of the case. **Q The writing that's under the driver's license that's in Chinese, what does that say?** A Please log in. If you like it, please 703-780-9559 Misty Klapper & Associates Page 92 share or leave a message. That's one of the function -- that's one of the function of Guo Media. Nothing to do with me. **Q Okay. All right.** MR. ALTMILLER: We'll take a break for a couple of minutes. VIDEO OPERATOR: We're going off the record at 12:59. (Thereupon, a recess was taken.) VIDEO OPERATOR: We're back on the record at 13:10. MR. MORRISSY: Just before we -- I know we were talking about breaks and we just took one and the need for nourishment, but on every break we take, we've sort of noticed a growing contingent of people outside and some from a media company that the Defendant has been known to give interviews with. And we believe that staying here for an extended period of time is a distinct threat to the safety of my client. So with that being said, you 703-780-9559 Misty Klapper & Associates Page 93 know, if you want to -- let's go through it and if you want to take a break to call your client and ask him to ask the media company to back off, that would probably also be a positive thing. MR. ALTMILLER: I'm -- I'm totally with you and -- and my co-counsel just spoke what I was thinking, which is, do you guys have a back door? MR. MORRISSY: None that I've used before. MR. ALTMILLER: Okay. Because I don't want to deal with that. MR. MORRISSY: Right. Well, I mean, it's -- it's your client, right. It's a company called AMD that -- well, you can try, but it's, you know, it's -- I don't know any more than you do, but I've been given information that leads me to logically believe that it wasn't us who called this company or the people from the Chinese Embassy that may be there. MR. ALTMILLER: I will -- I will grant you that the suspects will dwindle once we eliminate the people in this room so, let's --
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| 1 | MR. MORRISSY: What do you mean | 1 | So he used -- against the CCP, and he's |
| 2 | eliminate? | 2 | spoke against me, shows that he is a person who is |
| 3 | MR. ALTMILLER: What -- I said once we | 3 | anti-democracy, a killer of the democracy, including |
| 4 | eliminate the people in this room, the suspects | 4 | his actions today, summoned the media to -- to come |
| 5 | would dwindle. | 5 | here. So his intention was to have the communist |
| 6 | MR. LAUFER: The elevator says there's a | 6 | party's spy to kill me. |
| 7 | lower lobby, a lobby and there's a lower lobby. | 7 | MR. ALTMILLER: And I should just also |
| 8 | MR. MORRISSY: Um-hmm. | 8 | say that my co-counsel was just downstairs and we |
| 9 | MR. ALTMILLER: Well, I'm not going to | 9 | may have an update on that situation. |
| 10 | discuss escape plans. Let's -- we should -- | 10 | MR. LAUFER: Yeah. There's -- there's -- |
| 11 | let's -- | 11 | there's absolutely nobody out there and the security |
| 12 | MR. MORRISSY: I'm just saying, if -- you | 12 | detail has indicated that they have no concerns |
| 13 | know, we should power through because if my client's | 13 | about it. |
| 14 | security team believes that the risk is heightened | 14 | MR. MORRISSY: Well, the security detail |
| 15 | to the point where another authority needs to be | 15 | for my client isn't going to share with you their |
| 16 | called or he needs to be escorted out, that's going | 16 | concerns, first of all. And second of all, there's |
| 17 | to have to happen. So let's -- | 17 | absolutely people on the street. It's DC. Did you |
| 18 | MR. ALTMILLER: I hear you. | 18 | go from car to car and check who was in each car? |
| 19 | MR. MORRISSY: But we don't want that to | 19 | We don't really know. So we'll get pictures of |
| 20 | happen, so let's just move. | 20 | them. |
| 21 | MR. ALTMILLER: I'm just trying to do a | 21 | BY MR. ALTMILLER: |
| 22 | deposition. | 22 | Q
Okay. Did you -- did you state that the |
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| 1 | THE WITNESS: (Unintelligible.) Legal? | 1 | Defendant would have sex with an animal? |
| 2 | MR. ALTMILLER: For the record, I -- I -- | 2 | A
No. |
| 3 | I can't respond to a question that's -- that | 3 | Q
Have you said -- have you stated that |
| 4 | requests legal advice from a -- | 4 | Baosheng Guo has solicited prostitutes in Tokyo? |
| 5 | BY MR. ALTMILLER: | 5 | A
I didn't say he solicited a prostitute. |
| 6 | Q
All right. Let's -- let's move along. | 6 | I said that he went into strip club. Maybe it's a |
| 7 | You -- you stated that -- that Baosheng Guo is a | 7 | translation error. |
| 8 | killer of the democratic movement out to secure a | 8 | Q
Okay. I'm just asking. And why did you |
| 9 | show in Las Vegas? | 9 | state that Baosheng Guo went to a strip club? |
| 10 | A
Yes. | 10 | A
Because a comrade who supported me in |
| 11 | Q
And you believe that to be true; is that | 11 | Japan told me, plus Li Xioa Mu also told me that he |
| 12 | correct? | 12 | went to a strip club in Tokyo. I don't know if -- |
| 13 | A
Yes. | 13 | if it's a translation error, whether those people in |
| 14 | Q
How do you think that he is a killer of | 14 | the strip club are qualified or so-called |
| 15 | the democratic movement? | 15 | prostitute, but he listed the strip club. |
| 16 | A
Because he defrauded and then also fool | 16 | Additionally, he was the one who paid the |
| 17 | those people who come against CCP. And those people | 17 | bill. |
| 18 | who paid the price of their life and of their | 18 | Q
And -- and who are these -- these people |
| 19 | families, because in the past 70 years there's no | 19 | who told you that? |
| 20 | one like myself that is outspoken against the -- | 20 | A
Li Xioa Mu. He was the person who paid |
| 21 | against the -- the communist party and is | 21 | the expenses on his behalf when they went to the |
| 22 | anti-revolutionary. | 22 | strip club to see women strip their clothes off. |
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| 1 | Q
Okay. Did you ever state that Baosheng | 1 | party and those are not facts. |
| 2 | Guo was poor and would not be able to file suit or | 2 | Q
What is your current net worth? |
| 3 | defend a lawsuit? | 3 | A
Negative. |
| 4 | A
Yes, I said that. | 4 | Q
Okay. |
| 5 | Q
Did you state that the reason that | 5 | A
On many media outlet, I already said that |
| 6 | Baosheng Guo removed his complaint to federal court | 6 | I don't have any more money, even with -- my 13 |
| 7 | was so that he could hand pick a judge? | 7 | billion assets in my homeland was confiscated. So I |
| 8 | A
No, that's not what I said. No. | 8 | have negative assets and that's why I'm suiing. |
| 9 | Q
Did you make any statement about why | 9 | CHECK INTERPRETER: He said 1.3 billion. |
| 10 | Baosheng Guo would have removed the case to federal | 10 | (Cross talking in English and |
| 11 | court? | 11 | Chinese.) |
| 12 | A
I already answered your question. Guo | 12 | THE INTERPRETER: That's what he said, 13 |
| 13 | Baosheng was the one who tweeted the photos bragging | 13 | billion. |
| 14 | that they had a drink with this attorney who is a | 14 | CHECK INTERPRETER: Because what he said, |
| 15 | descendent of President Carter. So he was the one | 15 | (Chinese), that is 1.3 billion. But now that he |
| 16 | who tweeted that and that -- to show us that he also | 16 | corrected it, so -- |
| 17 | have the case moved to a different court. He | 17 | (Cross-talking.) |
| 18 | tweeted that the judge at this new court | 18 | THE WITNESS: Yeah, yeah, right. |
| 19 | discriminate against Chinese people; Asian people, | 19 | Thirteen billion is correct. You were correct. |
| 20 | especially Chinese. All of those move are | 20 | Thank you. I'm wrong. |
| 21 | disadvantageous to our case. He says this is the | 21 | BY MR. ALTMILLER: |
| 22 | end date of -- of ever Guo. | 22 | Q
So have you represented yourself in |
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| 1 | THE REPORTER: Of what? I'm sorry. | 1 | public as being a billionaire? |
| 2 | THE INTERPRETER: Referring to him. | 2 | A
Never. |
| 3 | THE WITNESS: Evil Guo, G-U-O, my first | 3 | Q
Okay. All right. Do you own any assets |
| 4 | name, yeah, family name. | 4 | in the United States? |
| 5 | THE INTERPRETER: Oh, evil Guo. | 5 | A
In reality, under the law, no. |
| 6 | THE WITNESS: He claimed that this -- the | 6 | Q
Do you receive any income from any |
| 7 | evil Guo's end date is here, he said, or he tweeted | 7 | sources? |
| 8 | it. But I'm still alive after meeting you guys | 8 | A
No. Communist party closed or seized all |
| 9 | after so long. You don't kill me. Thank you. | 9 | my accounts and credit cards, especially after Guo |
| 10 | BY MR. ALTMILLER: | 10 | Baosheng started his cooperation with the communist |
| 11 | Q
Do you -- do you have a United States | 11 | |
| | | | |
| | | | party and all my accounts were froze and I have not |
| 12 | passport? | 12 | a penny left. |
| 13 | A
No. | 13 | Q
How do you pay your expenses? |
| 14 | Q
Have you ever claimed that you had a | 14 | A
Borrowed. |
| 15 | United States passport? | 15 | Q
So you continue to borrow money now to -- |
| 16 | A
I never claimed that. | 16 | to pay your ongoing expenses? |
| 17 | Q
Did you ever state that you had a | 17 | A
Yes. |
| 18 | relationship with the first hacker in the world? | 18 | Q
Okay. Other than your interest in the |
| 19 | A
We are saying that we are in the process | 19 | fund that owns the companies that we discussed |
| 20 | of contacting the first hacker in the world for | 20 | earlier, do you own any assets or real estate in |
| 21 | anti-CCP. So don't take portions of my statement | 21 | your own name? |
| 22 | and twist it. That is too much like the communist | 22 | A
The apartment that I stayed in New York, |
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703-780-9559 Misty Klapper & Associates Page 102 781 Sherry-Netherland, was owned by the fund under my name, but it's not mine. (Court reporter clarifying.) (Thereupon, a discussion was had off the record.) BY MR. ALTMILLER: **Q And so the -- so the -- the apartment in -- in Manhattan is not in your name; is that correct?** A It's under my name, but I did not own it. **Q Okay.** A Or I do not own it. MR. MORRISSY: So, let's -- what does -- let's just talk about what under my name means because we're talking about a New York apartment. You're -- you're from up there. You know how things are done with co-ops and condos and -- MR. ALTMILLER: Yeah. I -- I have no idea what it means. MR. MORRISSY: Right. Does it matter to you? MR. ALTMILLER: I mean, I don't know what 703-780-9559 Misty Klapper & Associates Page 103 to make of it and so at some point -- I mean, I haven't checked the land records, so I don't know -- I don't know -- or the tax records, so I have no idea what it means. I don't know -- I don't know what to make of it, quite frankly. MR. MORRISSY: Yeah. It's all online with ACRIS, so -- MR. ALTMILLER: I just -- I have no idea. MR. MORRISSY: It's public information. MR. ALTMILLER: I mean, I'm not trying to be tricky. I was just -- I was just curious as I say -- MR. MORRISSY: No, and I wasn't insinuating that. I just wanted to clarify what my client said, you know. MR. ALTMILLER: He said it was in his name and he didn't own it. MR. MORRISSY: It's under his name. MR. ALTMILLER: Under his name. He didn't own it. MR. MORRISSY: Because I don't understand what that means. 703-780-9559 Misty Klapper & Associates Page 104 MR. ALTMILLER: Well -- MR. MORRISSY: I mean, he's allowed to live there pursuant to the co-op's rules. These are -- I'm just -- MR. PODHASKIE: So it's all public. So it's owned by an LLC technically. The shares are owned by an LLC and he -- then the LLC is then owned by a separate holding company and he is the owner of the holding company and then he also has assets by a proprietary lease the way a co-op is set up. It's not a condominium, so you don't own the real estate. You get shares and you get a lease to the apartment. MR. LAUFER: So he's a beneficial owner? MR. PODHASKIE: Correct. MR. ALTMILLER: So -- just to clarify, so he is -- the property is owned by an LLC that's owned by a holding company that in turn is owned by Mr. Guo? MR. PODHASKIE: Correct. BY MR. ALTMILLER: **Q Okay. Is that -- is that true?** MR. ALTMILLER: Can I just have the 703-780-9559 Misty Klapper & Associates Page 105 witness say that that's true? THE WITNESS: Yes. MR. ALTMILLER: Okay. So would it be -- so -- okay. All right. I'm not sure -- I'm not sure what to make of that because it then -- it suggests that he owns a -- he owns a company that owns a company that owns a \$65 million apartment. MR. MORRISSY: Well, who's valuing that apartment? MR. ALTMILLER: Well, that's a good question. So let's do this -- MR. MORRISSY: It wasn't purchased for that amount. MR. ALTMILLER: Let me -- that's -- that's a good point. Let's mark this as -- is it 4? Let's mark it as 4. (Whereupon, Deposition Exhibit Number 4 was marked for Identification.) BY MR. ALTMILLER: **Q So let me ask you this: You're aware that there was a -- a profile done of you by -- in**
Case 22-50073 Doc 404-30 Filed 05/20/22 Entered 05/20/22 11:52:18 Page 29 of
703-780-9559 Misty Klapper & Associates Page 106 **the New York Times Sunday Magazine?** A Yes. **Q For those of us who grew up in New York it's kind of a big deal.** THE REPORTER: I'm sorry. MR. ALTMILLER: I said, for those of us who grew up in New York, that's kind of a big deal. BY MR. ALTMILLER: **Q Anyway, what I -- what I -- what I wanted to ask you was this is -- I'll represent to you this is the -- the article that was written and I -- all -- all I wanted to -- to ask you about just to follow up with what we were discussing is a -- a part in here on the first page and in the second paragraph, which begins with: I have the best houses, and then it -- it talks about some other property that you own. And I -- I just wanted to ask if these statements in here are true?** MR. MORRISSY: Can we have these statements translated? THE WITNESS: Incorrect. MR. MORRISSY: Incorrect. There we go. 703-780-9559 Misty Klapper & Associates Page 107 MR. ALTMILLER: All right. That's -- that's -- that's all I was asking. Okay. Let's do this. Is that five? (Whereupon, Deposition Exhibit Number 5 was marked for Identification.) BY MR. ALTMILLER: **Q So what I've handed you marked as Exhibit 5 is a document I received yesterday afternoon or evening -- I think it was evening -- which are the most recent version of your objections and responses to Interrogatories. Have you seen these?** A I have seen it. I signed it. MR. ALTMILLER: Do we have a signed version? MR. MORRISSY: Yeah. This should be it. MR. ALTMILLER: Oh, there it is. Okay. Just not under oath. Okay. It's just signed. Okay. All right. MR. MORRISSY: He's under oath now. MR. ALTMILLER: Yes, he is. 703-780-9559 Misty Klapper & Associates Page 108 BY MR. ALTMILLER: **Q So -- so let me ask you. You read this and signed this. Do you attest that these answers are true and accurate to the best of your knowledge?** A Yes. **Q Okay.** A But due to the -- the time constraint, it was not translated in its entirety. It's only verbally conveyed to me, but the truth in there should be no problem. **Q Okay. I want to talk about the answer that you provided to Interrogatory Number 4, which begins on page 6. And in that Interrogatory you provide the names of people who are known to you who are witnesses of the events and allegations in the complaint and in the counterclaim. Are these all the people that you know that fit that description?** A It's accurate. **Q Is it Wayne Cao? Is that how it's pronounced?** A Wayne Cao, yes. 703-780-9559 Misty Klapper & Associates Page 109 **Q He -- he works for you?** A Yes. **Q Hank Han works for you?** A Yes. **Q Yvette Wang works for you?** A Partner? **Q And Robert Wang?** A No. A supporter. **Q Okay. All right. I want to -- I want to ask you -- I asked you earlier about the basis for the statements that you have made about Baosheng Guo. Have you given me all the facts that you are relying upon for making those statements? I'm only asking about the statements that I've asked you about, not -- not any statements I haven't asked you about.** A Yes. **Q Okay. You have sued Baosheng Guo for one million dollars for defamation. Is there a reason for that amount?** A I told you that during the Dalian lawsuit that -- the damage he caused me and my employees.
703-780-9559 Misty Klapper & Associates Page 110 Additionally, judge relied on the YouTube and the media information as the basis to determine that that -- the judge's decision. The damage that he caused us is far exceeding one million -- **Q Okay.** A -- including the assets located in Hong Kong that was being investigated or seized was all because of Guo Baosheng's YouTube and Twitter. Therefore, his damage to my family members, myself and all that involved far, far exceeded one million dollars. In the future we will seek to up that amount. MR. ALTMILLER: I'm going to take a break very quickly. I want to talk to my co-counsel. You guys can stay here. I'm -- I'm very close to being done, if not there. But I just want to -- I just want to confer with him outside. It's probably easier to do it that way. MR. MORRISSY: Okay. VIDEO OPERATOR: We're going off the record at 13:41. (Thereupon, a recess was 703-780-9559 Misty Klapper & Associates Page 111 taken.) VIDEO OPERATOR: We're back on the record at 13:48. (Whereupon, Deposition Exhibit Number 6 was marked for Identification.) BY MR. ALTMILLER: **Q I have handed you the most recent version of the Supplemental Responses to our Request for Production of Documents, which has been marked as Exhibit 6. Have you seen this document before?** A I have seen it. **Q If you could turn to page 4.** MR. MORRISSY: Well, let's just be clear for the record. The deponent doesn't read English. MR. ALTMILLER: Ooh. Okay. Well, that's a good point, by the way. That's a very good point. I did not know that. BY MR. ALTMILLER: **Q Well, let me ask -- let me ask this --** MR. MORRISSY: At least in a way that doesn't require a translator for this situation. 703-780-9559 Misty Klapper & Associates Page 112 MR. ALTMILLER: Okay. Well, I'm going to see if I can, notwithstanding that handicap, perhaps, get where I need to get. BY MR. ALTMILLER: **Q On page 4 you have provided -- in response to a request for the documents you used in drafting your Answers to Interrogatories, you have identified some YouTube video links. And pursuant to an agreement with counsel, we agreed that we wouldn't have to produce the -- the video, but we would produce the link. And the first thing I just want to ask is, did you provide these links?** A Yes. **Q And do you know what these YouTube videos are; in other words, what do they show?** A I am aware, but I am not familiar or understood all the English part of it. **Q Okay. And -- and just in general, what do those videos show?** A Well, that -- at that time when we prepared those documents, and really I am -- I don't 703-780-9559 Misty Klapper & Associates Page 113 remember the exact details of what those YouTube depict, but I think they're comprised of the insult that Guo Baosheng and something related to that -- he deny taking money from me, something like that. He make such a claim numerous times on YouTube. And that's the eighth reason I have to sue Guo Baosheng. And on public media number of times he denied he receive -- take money from me. So from that day I heard him say that I knew he's a liar. Many times he claim that he did not take a penny from me on YouTube. That's a lie. Therefore, he's a liar. I want to -- I want to stop him to cheat more people out of money and I want to stop him and that's the eighth reason I'm suiing him. **Q Now, it is true, is it not, that you do not have any transcripts of the YouTube postings that you claim are defamatory?** A No. **Q We requested documents related to your damage claim and you referred to the -- the YouTube**
703-780-9559 Misty Klapper & Associates Page 114 **links that you provided. And I have to ask you this because there's an objection lodged, so I need to know if there are any other documents for sure. Are there any other documents that demonstrate your damages in this case?** A Yes. We can provide you with more documents, so we need to make sure that we protect those people who are involved as well as those people's families in mainland China. Once the court granted us of -- such a protection, then we will provide them to you, because once the -- any of those information leak to the public, those people will -- people's life will be in danger. MR. MORRISSY: Given the response, I'm not sure that the question was understood completely. MR. ALTMILLER: Okay. I'll ask it again. All I can do is ask it. MR. MORRISSY: No. I hear you. I'm -- what can I say? I just -- that -- that answer didn't really -- was not really responsive to your question, although it began seemingly so. 703-780-9559 Misty Klapper & Associates Page 115 But can you point me to the -- the request number? MR. ALTMILLER: Sure. Request Number 15. MR. MORRISSY: So it's not only the YouTube links, but also the documents that were provided -- MR. ALTMILLER: Okay. MR. MORRISSY: -- that were -- that were referenced in response to the -- to the document requests. MR. ALTMILLER: Okay. So this is inaccurate when it says: See response to Request Number 1; there are other documents to which you refer? MR. MORRISSY: And -- and to the documents transmitted herewith. MR. ALTMILLER: And the documents transmitted herewith. Okay. MR. MORRISSY: Yeah. I just wanted to clarify. MR. ALTMILLER: No. That's true -- that's fair. Let me -- okay. 703-780-9559 Misty Klapper & Associates Page 116 BY MR. ALTMILLER: **Q Other than the documents that you have already produced to your attorney, are there any other documents that support your damage claims?** A Yes. **Q Okay. Other than the documents -- well, you know, let me -- I'm not going to -- that's going to be redundant. All right. Oh. Other than the documents that you have provided to your attorney, are there any other documents that demonstrate or show that Baosheng Guo is a public figure?** A No. **Q Okay. You testified that you have a -- a negative net worth. Are you in possession of documents that demonstrate what your net worth is?** A Yes. If you want it, I can show it. MR. ALTMILLER: I don't have anything further. THE WITNESS: Thank you, sir. MR. ALTMILLER: Thank you. THE WITNESS: Thank you, sir. Thank you. Thank you, sir. I really appreciate it. 703-780-9559 Misty Klapper & Associates Page 117 VIDEO OPERATOR: This deposition is completed and we're going off the record at 13:58. (Whereupon, signature having not been waived, at 1:58 p.m. the deposition concluded.)
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CERTIFICATE OF DEPONENT
CERTIFICATE OF NOTARY PUBLIC
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I, Carolyn E, Friend, the Officer before
I, Wengui Guo, do hereby certify that I have
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whom the foregoing Deposition was taken, do hereby
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read the foregoing pages, 4 through 117,
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certify that the witness whose testimony appears in
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inclusive, which contain a correct transcript
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of the answers given by me to the questions
the testimony of said witness was taken by me in
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propounded to me herein, except for changes, if
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stenotypy and thereafter reduced to typewriting by
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any, duly noted on the enclosed errata sheet.
me; that the said Deposition is a true record of the
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testimony given by said witness; that I am neither
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counsel for, related to, nor employed by any of the
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parties to this litigation; and further that I am
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counsel employed by the parties hereto, nor
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Sworn and subscribed to before me this ___ day
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Notary Public in and for
My commission expires:
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the District of Columbia
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My Commission Expires:
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October 31, 2019
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Case: Guo v. Guo.
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Deposition of: Wengui Guo.
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