郭文贵破产案 · EXHIBIT · ECF #440-18

元数据

当事人: 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
法院: CTB
案号: 22-50073
ECF #: 440
类型: EXHIBIT
立案日: 2022-05-25

原始法庭文件为英文，下方为英文全文。

全文

# **EXHIBIT PAX 20**

May 27, 2021 Hearing Transcript, *PAX v. Kwok*, Index. No. 652077/2017 (N.Y. Sup. Ct.), Dkt. 833

| | | 22-50073 | | |-----------------------|-----|----------------------------|----| | Ho Wan Kwok IN RE: | | | | | | | | | | | PAX | | 20 | | | | | | | | | 5/25/2022 Admitted in Full | | | | | P.E. | | | | | | | | | | | |

1 SUPREME COURT OF THE STATE OF NEW YORK **FILED: NEW YORK COUNTY CLERK 06/01/2021 04:48 PM** INDEX NO. 652077/2017 NYSCEF DOC. NO. 833 RECEIVED NYSCEF: 06/01/2021 Case 22-50073 Doc 440-18 Filed 05/25/22 Entered 05/26/22 15:30:37 Page 2 of 20

> 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 COUNTY OF NEW YORK : CIVIL TERM : PART 61 ------------------------------------------X PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P., Plaintiff, INDEX NO: -against- 652077/2017 KWOK HO WAN, a/k/a KWOK HO, a/k/a GWO WEN GUI, a/k/a GUO WENGUI, a/k/a GUO WENGUI, a/k/a WAN GUE HAOYUN, a/k/a MILES KWOK, a/k/a HAOYUN GUO, GENEVER HOLDINGS CORPORATION, and GENEVER HOLDINGS LLC, Defendants. ------------------------------------------X MICROSOFT TEAMS May 27, 2021 B E F O R E: THE HONORABLE BARRY OSTRAGER, J U S T I C E A P P E A R A N C E S: O'MELVENY & MYERS LLP Attorney for the Plaintiff Times Square Tower New York, New York 10036 BY: EDWARD MOSS, ESQ. STUART SARNOFF, ESQ. BAKER HOSTETLER, LLP Attorney for the Defendant 45 Rockefeller Plaza New York, New York 10111 BY: MELISSA CARVALHO, ESQ. JOHN SIEGAL, ESQ. LAWALL & MITCHELL, LLC Attorney for the Defendant GENEVER 162 E. 64th Street New York, New York 10065 BY: AARON A. MITCHELL, ESQ.

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| 1 | YANKWITT LLP | |----|--------------------------------------------------------------------------------| | 2 | Attorney for the Defendant 140 Grand Street, Suite 705 | | 3 | New York, New York NY BY: DANIEL ALTER ESQ. | | 4 | | | 5 | | | 6 | | | 7 | | | 8 | | | 9 | | | 10 | | | 11 | | | 12 | | | 13 | | | 14 | | | 15 | | | 16 | | | 17 | | | 18 | | | 19 | | | 20 | | | 21 | Karen Mangano, CSR | | 22 | Senior Court Reporter | | 23 | | | 24 | | | 25 | |

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Proceedings THE COURT: All right. Mr. Moss, this is your motion. MR. MOSS: Good afternoon, your Honor. We have two requests in our motion. One is compel discovery in response to a subpoena and the other is to modify the Court's restraining order. So I thought I would start with the subpoena. Your Honor, this might be the most straightforward issue that I've argued in front of this Court on this case. CPLR 5223 permits a broad range of discovery on any third party to request information that is relevant - relevant to enforcement of a judgment. As the Court knows, we've been forced -- my client has been forced to serve subpoenas on several third parties trying to find Mr. Kwok's assets because he doesn't hold them in his own name. Perhaps the most important subpoena Pacific Alliance served was a subpoena on an entity called Golden Springs. Golden Springs is a so-called family office for Mr. Kwok's family, but in reality, it is just Mr. Kwok's principal front. It's an entity that he funded entirely with his own money. It's an entity that pays all of the expenses for his lavish lifestyle. Every single expense by their own admission. It pays legal fees for a host of

| | Proceedings | |----|----------------------------------------------------------------------------------------------| | 1 | lawsuits for lawyers to represent Mr. Kwok in his individual | | 2 | capacity in cases in which Golden Springs is not even a | | 3 | party. | | 4 | It pays the legal fees of a lawyer who represents | | 5 | the entity that owns the yacht that's stonewalling me in | | 6 | discovery like the others. | | 7 | It pays the maintenance on the Sherry-Netherland | | 8 | apartment. We know all of this because Mr. Kwok and his | | 9 | lawyers admitted it in court filings and in discovery | | 10 | responses. | | 11 | I just want to put a fine point on it, your Honor. | | 12 | Mr. Kwok has no money or assets according to him, but he | | 13 | says he funded this entire entity and he uses it to pay | | 14 | every single one of his expenses, his living expenses. | | 15 | What are we talking about here, Judge? How is this | | 16 | discovery possibly not permitted under the CPLR? How is it | | 17 | not permitted relevant to enforce a judgment? | | 18 | The opposition that they filed, your Honor, it's a | | 19 | frivolous document, and I want to start with what's not in | | 20 | here. What's not in it is a dispute about any one of the | | 21 | facts that I just covered about Golden Springs. They ignore | | 22 | all of them. They can't dispute them because Mr. Kwok and | | 23 | his lawyers admitted them in discovery responses and in | | 24 | Court filings. So Golden Springs -- one of their arguments | | 25 | is well, we have corporate documents. We respect the |

Proceedings

| 1 | corporate forum. We have employees. But it doesn't dispute | |----|-----------------------------------------------------------------------------------------------| | 2 | that it only has one business which is to serve Highness | | 3 | Kwok. It doesn't even say what the business is besides a | | 4 | family office for his business. They say we have employees | | 5 | that include security. That's Mr. Kwok's bodyguard who | | 6 | comes to -- who comes with him to my office when I depose | | 7 | him and hands him bottled water because he's afraid that | | 8 | we're agents of the communists and my water at my firm is | | 9 | going to kill him. I mean, Judge, this is not a real | | 10 | company. They pay for Mr. Kwok's people. | | 11 | If Tim Cook got sued for something unrelating to | | 12 | his capacity in Apple, Apple doesn't pay those fees. Apple | | 13 | doesn't pay his maintenance. This is Mr. Kwok's piggy bank | | 14 | that he set up with his own money. | | 15 | The principal argument that is in Golden Spring's | | | |

papers is that Golden Springs is a third party and so we should only be entitled to information about assets that it holds for or transactions that it has conducted with Miles Kwok.

20 21 22 23 24 25 That's basically like saying it's a bank; right. You get that we subpoena the bank which we've done. We get Mr. Kwok's information, but we don't get information about the bank itself. We don't get information about the bank's other customers. That's a nice argument for a bank, but it completely ignores the context that Golden Springs is not a

# Proceedings

1 2 3 4 5 third party. It is the entity that holds Mr. Kwok's money, and it is the entity that pays his legal expenses. So it's assets are his assets. It's transactions are his transactions. And it's financial information is his financial information.

The suggestion in the papers that Mr. Kwok and Miss Wang and all of his people should be able to pick and choose and determine which information at Golden Springs relates to Mr. Kwok and which doesn't is a recipe for disaster here, Judge.

Mr. Kwok denies even being involved with Golden Springs. He denies being involved with the entity that owns the boat that we all know he owns because he said he owns the boat on YouTube, the boat which, by the way, is still out of the jurisdiction 15 days incurring \$500,000 a day.

Mr. Kwok is the same guy who denies owning his apartment that Miss Wang says -- told the Court under oath that he owns it.

So the limitation that they're trying to put in here, only things relating to Mr. Kwok, that's nonsense in this case, and it's just a recipe for us to get nothing.

22 23 24 25 Golden Springs also argues on the subpoena that we have to prove alterego to get discovery into it's assets. Well, that's just made up. There is no case to support that.

Proceedings

| 1 | 5223 is a broad standard. It's a generous | |----|------------------------------------------------------------------------------------------------| | 2 | standard. The Court ordered Miss Wang's information to be | | 3 | produced by the banks. They're not alteregos. She's not an | | 4 | alterego. Of course, we don't have to prove that it's an | | 5 | alterego to get it's information. | | 6 | The Court found that Miss Wang might be hiding Mr. | | 7 | Kwok's assets and gave us access to her financial | | 8 | information. This is much easier. He's already said it's | | 9 | his money, and he's using it to pay all of his expenses. I | | 10 | mean, there's no credible opposition to this motion. | | 11 | Finally, there's some arguments about scope. You | | 12 | know, I read it a few times. My subpoena is astounding. | | 13 | It's blunderbuss. It's a fishing expedition. It's | | 14 | flagrant. A lot of adjectives, but no substance. They | | 15 | don't articulate any burden arguments at all. | | 16 | Usually you say, Judge, well, we ran some search | | 17 | terms, and there are too many hits or this is going to be | | 18 | too burdensome to get because it's on a different server. | | 19 | Nothing. This is basically just a relevance argument that | | 20 | we're asking for too much. | | 21 | If they want to have a discussion about search | | 22 | terms and custodian and which laptops to collect, we welcome | | 23 | that discussion. We welcome an actual discussion about | | 24 | burden and scope. But not just saying, well, we think it's | | 25 | too much without any showing -- any showing at all that |

Proceedings

there is an actual burden.

I want to just end on one particular argument on the subpoena point because I expect Mr. Alter will focus on it. We ask -- we do. He's right. We ask for information about 60 people and entities, no one knowing to be associated with Kwok.

Mr. Alter quips in the brief, well, known by whom? Known by whom? Known by us, Judge. Known by us based on spending a lot of money and lot of time to dig through public records, court filings, social media accounts because that's the game Mr. Kwok has forced us to play.

12 13 14 15 16 17 18 19 20 21 22 23 The reason we have to ask for this information is because Golden Springs is the hub. We can't spend the rest of our lives chasing 100 entities. I mean, my grandkids would be doing this. Golden Springs is the entity that has the information. It's produced documents relating to Shiny Times, the entity that was involved in the underlying case. It has the documents. It is the hub of the empire. If it doesn't have information about a couple of these entities, if we're wrong about one or two, okay, fine. Then they should run the search and tell us they don't have it and not produce it. But run the search terms, collect the ESI and provide the documents.

24 25 THE COURT: All right, Mr. Moss. I understand your argument. I also understand that Mr. Kwok is incurring

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| | 9 Proceedings | |----|---------------------------------------------------------------------------------------------| | 1 | \$500,000 a day in contempt penalties. I understand that Mr. | | 2 | Kwok believes that these court proceedings are a game of | | 3 | evasion that he -- that he wants to play. | | 4 | And let me hear from counsel for Golden Springs. | | 5 | MR. ALTER: Good afternoon, your Honor. It's | | 6 | Daniel Alter, and we've just heard a lot of talk but | | 7 | relatively little truth, and I'd like to step back and | | 8 | clarify some issues that were quite muddied. | | 9 | First of all, to correct two specifically | | 10 | inaccurate statements, it's my understanding that Mr. Kwok | | 11 | has never said that he is entirely unrelated or has no | | 12 | connection to Golden Springs. Quite the opposite. He said | | 13 | that it is his family office. So let's be accurate about | | 14 | that. | | 15 | The second thing is that, you know, apparently -- | | 16 | they take the position that Mr. Kwok has entirely funded | | 17 | Golden Springs. Well, I don't see the evidence of that. | | 18 | What I see is a statement in the record that he initially | | 19 | provided capital to Golden Springs, but I see no evidence | | 20 | that he's continued to do so or that the capital there now | | 21 | is his. Let me step back a moment and talk about this. | | 22 | THE COURT: Before you do so, Mr. Alter, because | | 23 | rightly or wrongly, Mr. Kwok has exhausted the Court's | | 24 | patience with his antics. | | 25 | It's quite undisputed that Golden Springs has |

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Proceedings funded seven-figure payments to facilitate Mr. Kwok's lifestyle, and Mr. Kwok leads a rather extravagant lifestyle, purports to have zero assets whatsoever. So the plaintiff is a judgment creditor. The plaintiff knows that Golden Springs is funding expenses for Mr. Kwok. Not minor inconsequential expenses. Major expenses. And the judgment creditor is entitled to have discovery of the entity that is funding Mr. Kwok's expenses. The judgment creditor is also entitled to an order directing Golden Springs not to transfer, dispose or otherwise dissipate whatever assets Golden Springs has because the best evidence that has been made available to the Court compellingly suggests that any assets that Golden Springs has were provided to Golden Springs by Mr. Kwok. Now if the discovery that the judgment creditor is seeking from Golden Springs disproves that, well, then we have a different situation than the situation we now have. Under the CPLR, a judgment creditor is entitled to discovery of third parties of which in this case may well be

alteregos of Mr. Kwok, but it's not necessary for the judgment creditor to establish that Golden Springs is an alterego of Mr. Kwok.

23 24 25 MR. ALTER: You know, your Honor, we haven't - that's not our position. That's the straw man that has been presented.

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Spring.

| NYSCEF DOC. NO. 833 | RECEIVED NYSCEF: 06/01/2021 20 | |---------------------|-------------------------------------------------------------------------------------------------| | | 11 | | 1 | Proceedings THE COURT: Well, be that as it may, unless you can | | 2 | persuade me otherwise, I am granting the judgment creditor's | | | | | 3 | motions in their entirety. | | 4 | As Mr. Moss outlined, he is perfectly prepared to | | 5 | meet and confer and discuss limitations on specific requests | | 6 | that he's made if you can then state to him good cause for | | 7 | that. But we're past playing games here. | | 8 | MR. ALTER: Well, your Honor, I'm not here to play | | 9 | games, and if the Court has made it's decision, would it | | 10 | allow me to make my record. | | 11 | THE COURT: Yes. Make your record. | | 12 | MR. ALTER: Okay. Thank you, your Honor. | | 13 | First of all, our argument is not that you have to | | 14 | pierce the corporate veil in order to get third-party | | 15 | discovery under the CPLR for judgment creditors. It's a | | 16 | relevance argument, and we've already said that there are | | 17 | aspects such as discovery as between Golden Spring and the | | 18 | actual judgment debtor is relevant and appropriate. So we | | 19 | haven't taken a position that is all out of line with what | | 20 | the law provides. | | 21 | What we have said and what Mr. Moss has proven in | | 22 | his argument is they take the position that Mr. Kwok is | | 23 | Golden Spring and Golden Spring is Mr. Kwok; and therefore, | | 24 | they are entitled to go through the entire file of Golden |

# Proceedings

1 2 3 4 5 6 Well, you know, your Honor, that's called piercing the corporate veil, and it's our position that if they want documents independent of the judgment debtor where they make no connection or efforts to make a connection whatsoever, then, yes, they do have to pierce the corporate veil, but that isn't the sum total of our argument.

Our argument is that the requests are exceedingly overbroad and that they are irrelevant. And in fact, let's go for a moment to the facts that Mr. Moss says are overwhelming in this case.

If you look at the submission that was actually presented on this motion, there is absolutely no facts presented with regard to the 64 nonparties for which they seek discovery having nothing to do with the judgment debtor. Just -- not even having anything to do with Golden Spring. They just want discovery to 64 nonparties.

17 18 19 20 21 22 23 24 Now your Honor, we heard Mr. Moss say that he knows there is a connection. Well, wouldn't it be enlightening for the Court to know what that connection is before there is a ruling that Golden Spring has to produce documents that otherwise are clearly irrelevant. So that's why we assert that those documents should not be discovered unless and until Mr. Moss and PAX comes forward with actual proof that there is a connection. We don't have that.

And with regard to the proof, the overwhelming

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| | Proceedings | |----|--------------------------------------------------------------------------------------------------| | 1 | proof that Golden Spring is Mr. Kwok and Mr. Kwok is Golden | | 2 | Spring, at least from the record I've seen, your Honor, and | | 3 | I do not call your Honor's history -- historical | | 4 | recollection into question, but what has been presented on | | 5 | this record is Golden Spring initially helped to capitalize | | 6 | a company. A lot of folks do that. | | 7 | Secondly, Golden Spring pays for attorneys and has | | 8 | contributed to paying for apartment expenses. Well, okay. | | 9 | Three, employees of Golden Spring have attended | | 10 | family interests that have to do with the Guo family. Well, | | 11 | it's a family company. It's a family office. | | 12 | And Golden Spring's parent has apparently produced | | 13 | documents in response to discovery requests. So yes, | | 14 | there's a connection as Mr. Kwok has said, but there isn't | | 15 | an identity of entity between Mr. Kwok and Golden Spring, | | 16 | and that's why we referred in our papers to the fact that if | | 17 | that is the case, the law is very clear they do need to | | 18 | pierce the corporate veil and they absolutely would need to | | 19 | pierce the corporate veil to get injunction. Because as we | | 20 | stated, as much as the Court has lost patience, and I | | 21 | understand your Honor's position, the law is clear that an | | 22 | entity as a matter of due process can not be enjoined | | 23 | without actually being a party. | | 24 | And even if an entity were brought into a | | 25 | litigation as a party, the Courts are constrained. They can |

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# Proceedings

not grant prejudgment asset freezes, and that is exactly what PAX is trying to do now. They are trying to enjoin Golden Spring from expending any of it's own assets for any purpose, and that is contrary to the law.

5 6 7 8 9 10 11 12 13 14 Now, they argue that your Honor has a power to enforce restraining orders. Of course you do. And Golden Spring was served with a restraining order, and Golden Spring acts at it's peril if it transfers any property with which Mr. Kwok -- in which Mr. Kwok has an interest, but a Court's enforcement of a restraining notice is not the tantamount to an injunction. It's an after-the-fact litigation based upon allegations that there had been a violation of the notice. They're two entirely separate things.

So your Honor, respectfully, there isn't either a jurisdictional basis for the injunction nor is there a compelling factual basis for one because they have the relief that the CPLR has provided for.

Now, if the Court is going to go ahead and enter certain orders as your Honor has described, I request a few things, a few clarification points.

22 23 24 25 First of all, we would request the Court post a bond. Order that PAX post a bond. They are seeking an injunction against Golden Spring from using any of it's assets. And pursuant to the CPLR 6312(b), a bond is

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Proceedings 15 necessary. It's a necessary element for preliminary relief. So we would ask the Court direct that a bond be posted. We would also ask whether under this jurisdiction, Golden Spring is able to pay lawyers. Is it able to pay it's employees? Mr. Moss dismisses the fact that the company actually employs 16 employees and seven independent contractors. Are they not entitled to continue that? Do they need -- is this injunction going to close Golden Spring? We need that clarification because Golden Spring does not want to be in violation of your Honor's order. And finally, you know, your Honor, I would request respectfully a stay of the Court's order for a week so that we may seek appellate relief and seek a stay pending appeal. But given that this is, you know, a holiday weekend, we request that the Court stay because again, as I said, Golden Spring does not want to be in violation of this Court's order; but for all the reasons I've stated, honestly, your Honor, the relief requested is a function of facts that Mr. Moss has asserted as judge, jury and executioner. They haven't been presented. They haven't been adjudicated. They haven't been formally determined, all of which are necessary for the kind of relief for reaching into Golden Spring and setting aside it's individual identity and

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| | 16 Proceedings | |----|-------------------------------------------------------------------------------------------| | 1 | just securing whatever documents it wants and enjoining all | | 2 | of it's assets. That's necessary under the law. | | 3 | Thank you, your Honor. | | 4 | THE COURT: All right. I take your points. | | 5 | Nothing that you've said suggests that Golden | | 6 | Springs hasn't paid seven figures worth of Mr. Kwok's | | 7 | expenses in the immediate recent past. Nothing that you | | 8 | said alters the fact that Mr. Kwok flaunts the Court's | | 9 | orders at will. | | 10 | You're correct that PAX needs to post a \$500,000 | | 11 | bond. You're correct that I should stay these orders until | | 12 | June 1st at five p.m. to enable you to seek appellate | | 13 | relief, and you're correct that Golden Spring may pay it's | | 14 | employees in accordance with a schedule listing the identity | | 15 | of the employees and the amount of their compensation which | | 16 | you'll provide to Mr. Moss. And I think that addresses your | | 17 | concerns. | | 18 | MR. ALTER: With one exception, your Honor, and I | | 19 | appreciate the Court's response to those concerns. The | | 20 | attorneys. The attorneys that Golden Springs has been | | 21 | permitted here today to pay. | | 22 | THE COURT: There's no issue. Just need to | | 23 | identify the attorneys and the fees that you're paying to | | 24 | them. | | 25 | MR. ALTER: Okay. |

Proceedings

| 1 | THE COURT: And, you know, I note that Mr. Kwok has | |----|------------------------------------------------------------------------------------------| | 2 | apparently no concern for the \$500,000 a day sanction for | | 3 | flagrantly violating prior orders of the Court with respect | | 4 | to the boat that Golden Spring's is paying to maintain and | | 5 | transport. And if my calculation is correct, the total of | | 6 | the contempt sanctions to date is \$7.5 million. | | 7 | Mr. Kwok is just not free to live in New York at an | | 8 | ultra-luxurious condominium, the cost of which he's paid for | | 9 | by Golden Springs and ignore the processes of the New York | | 10 | courts. | | 11 | Now does anybody else wish to be heard? | | 12 | MR. MITCHELL: Your Honor, Aaron Mitchell. I | | 13 | represent the Genever defendants. Just one point of | | 14 | clarification. | | 15 | As you're well aware, your Honor, the Genever | | 16 | New York which owns the co-op is in bankruptcy so Golden | | 17 | Spring is not paying the maintenance for that apartment. | | 18 | I believe Mr. Moss is aware as well there was a | | 19 | security deposit paid which the surety is drawing down on | | 20 | which I just want to make that clear for the record. | | 21 | THE COURT: That is a fair and appropriate | | 22 | clarification. | | 23 | It doesn't alter the fact that prior to the fact | | 24 | that Genever which is another one of Mr. Kwok's many | | 25 | companies was paying for Mr. Kwok's luxury apartment. |

Proceedings

| 1 | Mr. Moss has been pursuing enforcement of a | |---|-------------------------------------------------------------------------------------------| | 2 | judgment for years now, and it's been my misfortune to have | | 3 | to have presided over these many, many, many motions and | | 4 | hearings, none of which are producing the results that the | | 5 | Court has ordered because Mr. Kwok directly or indirectly | | 6 | through his companies ignores Court orders. | | 7 | But Golden Springs presumably will comply with the |

But Golden Springs presumably will comply with the Court's order, and Golden Springs, you know, may seek a stay in the Appellate Division either tomorrow or today or on June 1. And if the Appellate Division stays the Court's order, then the Court's order will be stayed.

Otherwise, the Court expects Golden Springs to comply with the Court's orders subject to PAX's posting of \$500,000 bond in the event it's determined that there's any overreach here and subject to Golden Springs being able to pay identified lawyers and identified employees in accordance with the schedule.

MR. SARNOFF: Your Honor, this is Stuart Sarnoff. May I just ask one clarification?

THE COURT: Yes.

21 22 23 24 MR. SARNOFF: The obligation of PAX to post a bond, is that specifically in respect of the restraining order part of the -- of your decision today? THE COURT: Yes.

MR. SARNOFF: And separate -- so there is no --

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| | Proceedings | |----|-----------------------------------------------------------------------------------------------------| | 1 | THE COURT: With respect to the restraining order. | | 2 | MR. SARNOFF: So there is no -- there is no stay | | 3 | with respect to the obligation of Golden Spring to comply | | 4 | with the subpoena. Is that correct? | | 5 | THE COURT: That's correct. | | 6 | MR. SARNOFF: Thank you, sir. | | 7 | THE COURT: Anything else from anybody else? | | 8 | All right. The Court will enter a memorandum order | | 9 | consistent with the transcript of the proceedings of today. | | 10 | I would strongly urge counsel to order an expedited copy of | | 11 | the transcript of proceedings of today so that in the event | | 12 | Golden Springs seeks a stay from the the Appellate Division, | | 13 | there is a clear record reflecting what the Court has | | 14 | ordered. | | 15 | Have a nice day and a nice weekend. Everybody stay | | 16 | safe and thank you. | | 17 | | | 18 | CERTIFIED TO BE A TRUE AND ACCURATE TRANSCRIPT OF THE ORIGINAL MINUTES TAKEN OF THIS PROCEEDING. | | 19 | | | 20 | | | 21 | | | 22 | ______________________________ KAREN MANGANO, CSR | | 23 | Senior Court Reporter SO ORDERED: June 1, 2021 | | 24 | | | 25 | | | | KM |