郭文贵破产案 · EXHIBIT · ECF #477-1

# **EXHIBIT A**

**FILED: NEW YORK COUNTY CLERK 07/16/2018 09:51 AM** INDEX NO. 152123/2018 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 07/16/2018 Case 22-50073 Doc 477-1 Filed 06/20/22 Entered 06/20/22 21:12:25 Page 2 of 21

> SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK

ZHENG WU a/k/a BRUNO WU and YANG LAN,

--------------------------------------------------------------X

Index No. 0152123/2018

-against-

### AMENDED COMPLAINT

GUO WENGUI a/k/a MILES KWOK, Justice Assigned: Hon. Barbara Jaffe

Defendant. --------------------------------------------------------------XX

Plaintiffs Zheng Wu, a/k/a Bruno Wu, and Yang Lan, by their attorneys Arkin Solbakken

LLP, as and for their complaint against Defendant Guo Wengui, hereby state as follows:

Plaintiffs,

### PRELIMINARY STATEMENT

1. This action is brought against Defendant Guo Wengui ("Guo"), a citizen of numerous countries including Hong Kong, the United Arab Emirates, and the Republic of Malta, who-after having been accused and convicted of a broad array of criminal acts-fled to the United States with the hope of purchasing for himself the type of unofficial asylum reserved for those of extreme wealth.

2. Indeed, notwithstanding evidence tying Guo to money laundering schemes, forgery, bribery and physical and sexual assault, Guo has been able to obtain temporary refuge from his crimes in the United States, where he purchased a penthouse apartment in the prestigious Sherry Netherland at 781 Fifth Avenue, New York, New York for which he paid — \$67.5 million in cash.

3. With this new home becoming a base of operation, Guo commenced his propaganda campaign designed to meet his twin objectives of obfuscating his criminality and increasing the odds that his pending political asylum application is granted.

"China" 4. In particular, Guo has sought to define himself as a liberal-minded refugee by dribbling out over social media largely nonsensical claims of purported acts of corruption and high drama within the People's Republic of China ("PRC" or "China").

5. By these yarns, Guo pitches himself as a "pioneer of using YouTube and Twitter tofight for the rule of law, human rights, freedom and democracy in China."

6. But in reality, Guo is nothing more than a two bit con-man.

7. His "revelatory" claims of political corruption are little more than cheap and defamatory falsehoods about the personal lives of various Chinese and American citizens that Guo hopes to paint as antagonists of soap operatic proportions, and which he then feeds to his millions of "followers."

8. Guo does not expose "corruption"; instead, he uses the internet as an extension of his chaotic and criminal enterprise.

9. Thus, this action was originally brought in March 2018, by filing of the Summons and Complaint, to hold Guo to account for his wanton and malicious acts of defamation and to compensate those his deluded efforts have harmed.

10. Far from curtailing his activities, however, in response to this case, Defendant Guo has actually stepped up his attempts to silence Plaintiffs, and has now conspired with third parties, including, but not limited to, his own son Mileson Guo and others, to assist him in what has become a world-wide campaign of bullying and intimidation.

11. Accordingly, this Amended Complaint is being filed to address Guo's continuing and escalating misconduct, which has now veered into a conspiratorial attack on Plaintiffs.

### JURISDICTION AND VENUE

12. Pursuant to CPLR 301 and CPLR 302, this Court has jurisdiction over Guo because he is a resident of, and regularly conducts business in, New York County and New York State.

13. Pursuant to CPLR 503(a), venue is proper because Guo resides in New York County and has been actively publishing defamatory statements from his residence in this County.

### THE PARTIES

14. Plaintiff Zheng Wu is successful Chinese-American investor and media entrepreneur and a published author.

15. Plaintiff Zheng Wu also serves as a member of the intentional board of Museum of Television & Radio in New York & Los Angeles.

16. Plaintiff Zheng holds a Bachelor's degree in business management from Culver-Stockton College of Missouri, a Master's degree in international relations from Washington University in St. Louis, and a Doctor of Philosophy (Ph.D.) from the School of International Relations and Public Affairs at Fudan University.

17. Plaintiff Yang Lan is a leading broadcast journalist and media entrepreneur in China, well-known for her focus on social and cultural issues.

18. Plaintiff Yang Lan was recognized by Forbes as one of the world's 100 most powerful women.

19. Plaintiff Yang Lan has a Bachelor's degree in English language and literature from Beijing Foreign Studies University and a Master's degree in international affairs from Columbia University.

20. Plaintiffs have been married for twenty-three years and reside together in Beijing, China. Throughout their marriage, Plaintiffs worked together on numerous business and charitable ventures.

(" Stars" 21. For example, Plaintiffs co-founded Sun Seven Stars Capital Group ("Seven Stars"), through its predecessor Sun Media Group Holdings Limited, in 1999 and developed the company into one of the leading entertainment, media, and investment companies in Asia.

22. Seven Stars has a presence in over 10 major cities around the world and earns billions of dollars in sales annually.

23. Plaintiff Zheng Wu serves as Seven Stars' Co-Chair and Chief Executive Officer.

24. Plaintiff Yang Lan serves as Seven Stars' Co-Chair.

25. Plaintiffs also worked together in support of charitable organizations, including co-founding the Sun Culture Foundation which focuses on providing equal educational opportunities for underprivileged children and sponsoring Beijing's "Giving Pledge" event with the Bill & Melinda Gates Foundation.

26. Defendant Guo is a billionaire who purports to have made his money in various real estate ventures in China, and who now lives in "self-imposed exile" in New York City. Guo has sought permanent residence in the United States via an application for asylum, predicated on nonsensical claims levied by him in an effort to present himself to the United States government as a political refugee.

27. Guo possesses passports from numerous countries, including those from Hong Kong, the United Arab Emirates, and the Republic of Malta, and uses a number of aliases, including Guo Wen Gui, Guo Haoyun and Miles Kwok, among others.

28. Guo also maintains and controls a number of media accounts, including a Twitter account with the handle @KwokMiles (which has approximately 494,000 followers) and at least two YouTube accounts under the usernames "Miles Kwok" (which has approximately 11,000 subscribers) and "\$[¤Cÿt" (which has approximately 174,678 subscribers).

### FACTUALBACKGROUND

29. Contrary to victimology cultivated by Guo through media manipulation, he is not now, nor has he ever been, a political prisoner of the PRC.

30. Instead, Guo's relationship with the criminal authorities first began when he was approximately 18 years old and convicted of fraud, whereupon he was imprisoned along with others determined to be guilty of acts of petty thievery.

31. Guo was not, as he otherwise contends, jailed with "pro-democracy activists and political dissidents."

32. Subsequent to this period of incarceration, Guo went on to engage in increasingly more sophisticated financial frauds, concocting Ponzi schemes designed to enrich himself personally, to the detriment of his unwitting victims and the unfortunate business "partners" he ultimately turned against.

33. For example, Guo engaged in a series of fraudulent transactions whereby hundreds of millions of dollars were fraudulently obtained from the Agricultural Bank of China through the use of fake contracts, false receipts and creative interpretations of the word "leverage."

34. Guo also undertook efforts to work with officials from (and ultimately began to work for) China's Ministry of State Security ("MSS"), China's central intelligence agency with both domestic and foreign jurisdiction.

35. In particular, Guo struck up a close relationship with MSS leader Ma Jian, which resulted in Guo's participation in a number of covert and illegal acts, including "investigations" targeting Chinese nationals and United States political leaders, for which Guo has received medals from his MSS colleagues.

36. Other Guo associates are now, like Ma Jian, under investigation or prosecution for bribery and abuse of power crimes, including Zhang Yue, who acted as the Head of the Politics and Law Committee in China's Hebei Province, and Meng Huiqing, who was an official with CPC's Ant-Corruption Commission.

37. But Guo's acts were not predicated on Guo's belief in any particular political philosophy; instead, like everything else Guo undertakes, he sought to benefit personally from his relationship with the government, particularly with corrupt officials in intelligence and law enforcement agencies.

38. This included telling those he was assisting in investigating that he might obtain lighter sentences for them - so long as they transferred over to Guo their assets for Guo's personal use.

39. Guo also took as many precautions as he could to insulate himself from having to answer for his double dealing, often recording or video-taping government officials or business colleagues and acquaintances with sex workers Guo himself employed and planted - recordings he then used as a means of extortion.

40. And when politics in China changed, so did Guo's "loyalty."

41. Indeed, on more than one occasion Guo has promised allegiance to the PRC if onlytheywill take him back with the promise of no prosecution.

42. In exchange for special treatment by the PRC, Guo also (a) promised to provide the location of various Chinese political dissidents in the United States, (b) spied on and wiretapped various government figures, including former United States Secretary of Homeland Security Jeh Charles Johnson and former United Kingdom Prime Minister Tony Blair, for which he has received MSS medals, and (c) colluded with various terrorist organizations.

43. Far from being the anti-government crusader that he portrays himself to be from his comfortable surroundings in New York City, Guo was and is more than happy to remain an agent of the government that he now claims to hate - so longas there is somethingin it for him.

#### GUO IS OUTED BY THE MEDIA

44. Eventually, the story of Guo's wrongdoing and the toxicity of associating with him came to light by and through the press.

45. In particular, in 2015, a watershed expose was published by Caixin Media Company Ltd, implicating Guo in a conspiracy to oust Beijing's mayor and various other potentiallywrongful acts he had undertaken.

46. This same article reported on Guo's plan to video the deputy mayor of Beijing's private sexual activities as part of a scheme to discredit the municipality's political leaders and to enable Guo to acquire development rights to a plaza located near the Bird's Nest stadium in the Olympic Park of Beijing.

47. By at least one account, Caixin's coverage lead to an article that became the most widelyread article in the historyof Chinese journalism.

48. Moreover, media outlets began reporting in April 2017 that former MSS leader Ma Jian abused his power between 2008 and 2014 to jail, extort, or seize the property of Guo's business rivals in exchange for millions of dollars in bribes from Guo.

49. The media also reported that Guo paid millions of dollars to former Hebei Provincial Police Chief Zhang Yue, who in return interfered with and investigated Guo's business rivals, allowing Guo to obtain favorable deal terms or shutting out competition.

50. As a result of these reports and follow-on reporting, Guo was thrust into the international discourse.

51. Guo's crimes, too, have garnered international attention, with reports of a Red Notice havingbeen issued byInterpol in April 2017.1

### GUO'S DUPLICITY AND RETALIATION

52. As noted above, Guo fled the PRC to avoid answering for his crimes.

53. Since that time, he has made numerous efforts to "buy" his way back into his home country in a way that would allow him to avoid jail time -- including but not limited to letters written to the Chinese government that beg for a homecoming and which pledge allegiance to the PRC.

54. Always one to hedge his bets, however, simultaneously Guo has unleashed a series of schemes designed to afford him respite in the United States.

55. Chief among these schemes was Guo's decision to develop a fan base cultivated by attacks, perpetrated over social media, on the PRC, the press agents that have reported on his "business practices" in China, and anyone else, including Plaintiffs, who he believes (rightly or

A "Red Notice" is defined by Interpol as "a request to locate and provisionally arrest an individual pending extradition."

wrongly) might have information which could negatively influence his ability to remain safely ensconced on his billionaire perch in New York City.

56. Notably, Guo seems to take particular pleasure in defaming females, primarily by implicating them in sexual acts (that have never taken place) but which would act to embarrass, humiliate and harm their reputations.

57. Guo's misogynist protocol also carries with it the benefit of potential embarrassment to the partners and children of his targets.

58. For example, Guo used his social media accounts to attack Hu Shuli, the founder and Chief Executive of Caixin, a former Knight Journalism Fellow at Stanford, and a wellrespected journalist.

59. In particular, Guo indicated that Ms. Hu engaged in "sex [abuse] games" with various Chinese officials. Ms. Hu has denied any such sexual activity or relationship, and her defamation suit (in which Caixin is a co-Plaintiff) is pending before this Court. See Caixin Media CompanyLtd , et al. v. Wengui, Index. No. 652154-2017 (N.Y. Sup. Ct. N.Y. Cty. 2017).

60. Similarly, Guo has targeted Huang Yan, a female Chinese government official. By Ms. Huang's defamation claim (which is also pending in this Court), Guo is accused of egregious misstatements about her sex life, including but not limited to claims that she attained her position by engaging in sexual favors. See Huang Yan v. Wengui, Index No. 156552/2017 (N.Y. Sup. Ct. N.Y. Cty. 2017).

61. Regrettably, this is just a small sample of those targeted by Guo's infatuation with female sexuality. Others victimized include Fan Bingbing, Xu Qing, Gao Yanyan, Li Bingbing, Lin ZhilingDong Qing, Li Sisi, Mei Tong, Wanf Fang, Shu Xiaoquing, Zeng Chang, and (as described more fully below), Plaintiff Yang Lan.

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### GUO TARGETS PLAINTIFFS

62. Commencing in 2017, Guo began targeting Plaintiffs.

#### A.Guo's Defamatory Statements About Plaintiff Yang Lan

women' 63. Plaintiff Yang Lan is a household name in China and a leading broadcast journalist and media entrepreneur devoted to promoting general equality and women's professional development.

64. For example, Plaintiff Yang Lan created a talk show called "Yang Lan Studio," now named "Yang Lan One on One," which has become China's longest-running in-depth talk show, with more than 900 interviews with leaders from around the world.

women' 65. Plaintiff Yang Lan also created "Her Village," a television show geared towards a Chinese urban female audience, which seeks to promote gender equality and women's professional development through online and off-line educational programs.

66. For reasons that remain unclear, Guo believes Plaintiff Yang Lan is a threat to his political asylum application and his continued stayhere in the United States.

67. Accordingly, Guo has sought to tarnish Plaintiff Yang Lan's reputation as a successful female media entrepreneur and role model to women in China by publishing sexfocused defamatory statements about Plaintiff Yang Lan. This is Guo's modus operandi.

68. For example, on September 15, 2017, Guo published a video recording of himself to his "\$[¤C\$1" YouTube account wherein Guo stated that Plaintiff Yang Lan (a) maintained many "lovers" and engaged in an extra marital affair with "her sexual Xinjiang boyfriend," (b) "used genitals to build this powerful relation of law and order" and had extra marital affairs with Meng Jianzhu and Sun Lijun in exchange for the privilege of "presid[ing] over major national events," (c) had extra marital affairs with "sexually perverted" government officials "which led

to her uterine cancer," and (d) "secretly had surgery on her uterine cancer in Beijing Concord Hospital."

69. This video has been viewed over 296,220 times since Guo published it and is still available for viewing on YouTube.

70. On September 16, 2017, Guo stated in a live-streamed YouTube video that (a) "Yang Lan's Sun TV is for money-laundering and money scam" and (b) "Yang Lan deceived people by helping the great afforestation."

71. This video has been viewed over 380,499 times and is still available for viewing on Youtube.

72. On September 19, 2017, Guo stated in a live-streamed YouTube interview with Chen Xiaoping on Youtube user Mingjing Huopai's account2 account that Plaintiff Yang Lan (a) has "serious sexually transmitted diseases," (b) is "full of [sexually transmitted] diseases," (c) "sleeps with men who suffer[] from skin diseases," (d) had an extra marital affair with "Meng Jianzhu" which was filmed and "will shock everyone," (e) "has infectious and erosive uterine cancer," (f) has engaged in numerous extra marital affairs, and (g) "asks [her husband] to take her to sleepwith men from home and abroad."

73. The video of this interview has been viewed at least 385,459 times and is still available for viewing on YouTube.

74. These statements are entirely false and defamatory.

75. Guo was aware of the falsity of these statements at the time that he made them, or at the least, he has made these statements with reckless disregard for their falsity.

#### B. Guo's Defamatory Statements About Plaintiff Zheng Wu

2 YouTube user Mingjing Huopai has approximately 130,545 subscribers.

76. Guo also believes that Plaintiff Zheng Wu is a threat to his political asylum application and his continued stay here in the United States. Accordingly, Guo has sought to tarnish Plaintiff Zheng Wu's reputation largely by falsely accusing Plaintiff Zheng Wu of horrific crimes and heinous acts against children.

77. For example, on September 15, 2017, Guo published a video recording of himself to his "\$ͤCM" YouTube account wherein Guo stated that Plaintiff Zheng Wu (a) "came to the United States to find all those who may be close to [Guo] and those who know [Guo]" and then "wanted to pay to have [Guo] killed," (b) kidnapped Fu Zhenghua, (c) "is a typical Chinese trained spy," (d) tried to bribe Guo's attorney with "\$10 million to fight against Guo," (e) sought tohire "mafia killers" to kill Guo, (f) "continue[s] to hire to murder" in New York, and (g) "participated in [the] killing of Lei Yang" (a 29 year-old Chinese environmentalist who died while in police custody), (h) hired Li Dong "to eliminate all people who were aware of' money that Guo purports Plaintiff Zheng Wu received "overseas as the political stability fee," (i) has fathered "illegitimate children abroad," and (j) is a "gangster[]."

78. This video has been viewed over 296,220 times since Guo published it and is still available for viewingon YouTube.

79. On September 16, 2017, Guo stated in a live-streamed YouTube video that "Wu Zheng's academic credentials are fabricated."

80. This video has been viewed over 380,499 times and is still available for viewing on Youtube.

81. On September 19, 2017, Guo stated in a live-streamed YouTube interview with Chen Xiaoping on Youtube user Mingjing Huopai's account that Plaintiff Zheng Wu (a) participated in the murder of Lei Yang, (b) participated in a criminal conspiracy involving the

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raping of children, (c) asked his wife, Plaintiff Yang Lan, "to sleep with [a British] foreigner while he watched the door," (d) used his wife as a "sex tool" and took his wife "time and time again" to sleepwith foreign officials, and (e) "is a trained spy of Shanghai."

82. The video of this interview has been viewed at least 385,459 times and is still available for viewingon YouTube.

83. These statements are entirelyfalse and defamatory.

84. Guo was aware of the falsity of these statements at the time that he made them, or at the least, he has made these statements with reckless disregard for their falsity.

85. For example, approximately one-third of the way into the September 19, 2017 live-streamed YouTube interview, Chen Xiaoping cautioned Guo that Plaintiff Zheng Wu "will sue [Guo]" if Guo continued with his defamatory statements about Plaintiff Zheng Wu. Guo responded by saying "[d]on't worry, I especially welcome him to sue me," and then continued makingdefamatorystatements about Plaintiffs.

86. Thereafter, on May 9, 2018, Guo made the following posting on Guomedia.com: "Dear comrades: Wu Zheng has been in New York for a week! He is telling the story about his grandfather saving tens of thousands of Jews again! And continue to develop his espionage network! Continue to Lan-Jin-Huang (blue-gold-yellow) the United States! And attend his family member's graduation! After meeting his lover in London, Miss Nana...... he came to New York again! What's the purpose of opening the club......I will send the photos of the video screenshots to Ms. YangLan! Everythinghas just begun".

87. "Blue-gold-yellow" is a term Guo uses to describe the PRC's tactics to target individuals - through bribes, blackmail and other nefarious means - and to coerce them to work for the PRC government.

88. These statements, including the multiple statements that Plaintiff Wu is a spy and that Plaintiff Wu is an adulterer,are entirelyfalse and defamatory.

89. Guo was aware of the falsity of these statements at the time that he made them, or at the least, he has made these statements with reckless disregard for their falsity.

90. Moreover, this posting also reveals that Guo, either personally or in conspiracy with other third parties, was secretly following and monitoring Plaintiffs' activities in New York, including making specific references to Plaintiffs' personal family affairs.

### GUO'S THREATS OF VIOLENCE

91. In addition to the foregoing, Guo has taken to implicitly threatening or directly encouragingviolence as against Plaintiffs.

92. For example, in the September 19, 2017 live-streamed YouTube interview with Chen Xiaoping, Guo suggested that Plaintiff Yang Lan will "not be able to live a long life," and that she may "disappear at any time."

93. In the same breath, Guo also stated that Plaintiff Zheng Wu "may be killed at any time as he did too many bad things, he may get into a car accident or die of disease at any time, both are possible."

94. As to when such harm might befall either of the Plaintiffs, Guo went on to state: "[r]ight now, [I] cannot give any specific details."

#### GUO ESCALATES THE CAMPAIGN TO INTIMIDATE PLAINTIFFS AFTER INSTITUTION OF THIS CASE

95. This action was commenced against Guo in March 2018.

96. However, far from curtailing his activity as a result of that filing, Guo has gotten more desperate and engaged in further, more drastic acts of threatened violence, intimidation and stalking.

97. In a new twist, and in an escalation of his intimidation campaign, Guo enlisted third parties, including his son Guo Mileson ("Mileson"), into his plot to physically intimidate and silence Plaintiffs.

98. Specifically, on or about April 6, 2018, Plaintiffs and their family were dining at a restaurant named Estiatorio Milos in London, U.K.

99. In a deliberate attempt to intimidate Plaintiffs, Mileson and a cohort of threatening bodyguards, at the instance and direction of Defendant Guo, secured four tables surrounding Plaintiffs, their family and their dining companions.

100. Then, while Plaintiffs, their family were dining, Mileson took photographs of Plaintiff ZhengWu,his familyand his diningcompanions.

101. Thereafter, Defendant Guo posted these photographs of Plaintiffs and their family and dining companions eating dinner.

102. The circumstances under which Mileson and his cohorts surrounded Plaintiffs and took these photographs demonstrate that Defendant Guo, or third parties on his behalf, had engaged in some manner of surveillance of and/or eavesdropping on Plaintiffs.

103. Specifically, Plaintiffs' reservation at Estiatorio Milos was under the name of a third party, not either of the Plaintiffs.

104. Moreover, the identity of the party that made the reservation was only known by Plaintiffs and their other diningcompanions.

105. In fact, the identity of the person making the reservation was not even known to the restaurant itself until approximately 3 hours prior to Plaintiffs' seating.

106. Accordingly, this information must have been was ascertained though some form of eavesdropping or other invasive and threatening monitoring of Plaintiffs, either physically or electronically.

107. In addition to this conduct in London, as noted above, Guo's May 9, 2018 posting demonstrates that Guo, either himself or through others, was surveilling Plaintiffs during their trip to New York.

108. Directly as a result of this conduct directed by Guo, Plaintiffs have suffered severe emotional distress, shame, anxiety, emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life, and other non-pecuniary losses as set forth hereinabove.

### FIRST CAUSE OF ACTION

### (Defamation Per Se)

109. Plaintiffs incorporate by reference all preceding and succeeding paragraphs of this Complaint.

110. Through speech, postings to social media accounts and websites, and various other writings, Guo has falsely and with malice repeatedly defamed Plaintiffs, including but not limited to statements meant to convey (i) that Plaintiffs have and continue to engage in outrageous acts of criminality, such as murder and the raping of children, (ii) that Plaintiff Yang Lan has sexually transmitted diseases, and (iii) that Plaintiff Yang Lan engaged in extra marital affairs to advance her career.

111. These statements have damaged Plaintiffs' reputations among a large number of people, and have caused them to associate Plaintiffs with sexual depravity, promiscuity, and criminal behavior.

112. Guo knows these statements are false, or has at least acted with reckless disregard as to the truth of such statements.

113. Guo made these statements with the intent of maliciously damaging Plaintiffs and their reputations, harming their business interests and to induce others to not do business with them.

114. Guo had neither the authorization nor the privilege to make such statements.

### SECOND CAUSE OF ACTION

## (Defamation)

115. Plaintiffs incorporate by reference all preceding and succeeding paragraphs of this Complaint.

116. Through speech, postings to social media accounts and websites, and various other writings, Guo has falsely and with malice repeatedly defamed Plaintiffs, including but not limited to statements meant to convey (i) that Plaintiffs have and continue to engage in outrageous acts of criminality, such as murder and the raping of children, (ii) that Plaintiff Yang Lan has sexually transmitted diseases, and (iii) that Plaintiff Yang Lan engaged in extra marital affairs to advance her career.

117. These statements have damaged Plaintiffs' reputations among a large number of people, and have caused them to associate Plaintiffs with sexual depravity, promiscuity, and criminal behavior.

118. Guo knows these statements are false, or has at least acted with reckless disregard as to the truth of such statements.

119. Guo made these statements with the intent of damaging Plaintiffs and their reputations, harming their business interests and to induce others to not do business with them. 120. Guo had neither the authorization nor the privilege to make such statements.

121. Plaintiffs have suffered harm as a result of Defendant's conduct, in a monetary amounttobedeterminedattrial.

### THIRD CAUSE OF ACTION

(Intentional Infliction of Emotional Distress)

122. Guo made these statements, as well as the others identified above, with the intent tocause severe emotional distress to Plaintiffs, or at the least, he has made these statements while recklessly disregarding the substantial likelihood that they would cause Plaintiffs emotional distress.

123. Moreover, Guo has engaged third parties, including his own son Mileson, to follow Plaintiffs and/or to electronically and/or physically surveil them on his behalf.

124. Directly as a result of this conduct directed by Guo, Plaintiffs have suffered severe emotional distress, shame, anxiety, emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life, and other non-pecuniary losses as set forth hereinabove.

125. Directly because of the false and outrageous statements publicized as discussed above, Plaintiffs have experienced emotional distress, shame, repeated bouts of anxiety, inconvenience, mental anguish, loss of enjoyment of life and other non-pecuniary losses.

### FOURTH CAUSE OF ACTION

### (Conspiracy to Intentionally Inflict Emotional Distress)

126. Plaintiffs incorporate herein by reference all preceding and succeeding paragraphs as if fully set forth herein at length.

127. As set forth hereinabove, Guo has engaged in a scheme to harass, intimidate and defame Plaintiffs and thereby cause them severe emotional distress.

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128. Guo has conspired with third parties to facilitate and implement his nefarious scheme, including, but not limited to his son Mileson Guo and unidentified bodyguards.

129. For example, Guo has engaged said third parties, including his own son Mileson Guo, to follow Plaintiffs and/or to electronicallyand/or physicallysurveil them.

130. By directing these third parties to undertake this conduct, and by then publicly posting secretly taken photographs, Guo took overt acts in furtherance of the conspiracy.

131. As a result of this conspiracy and this conduct, Plaintiffs have suffered severe emotional distress, shame, anxiety, emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life, and other non-pecuniarylosses as set forth hereinabove.

132. As a result, Plaintiffs have been damaged in an amount to be determined at trial. WHEREFORE, Plaintiffs request entry of Judgment in their favor and against

Defendant as follows:

- (i) compensatory and punitive damages in an amount to be determined at trial, but no less than \$10 million; - (ii) enjoining Defendant and anyone acting or purporting to act on his behalf from making any of the false and defamatory statements set forth herein, or similarly false and defamatorystatements involvingPlaintiffs;

(iii)punitive damages;

- (iv)the costs and expenses incurred in this action includingattorneys' fees; and - (v)such other and further relief as the Court deems just and proper.

Dated: July 16, 2018

I ARKIN SOLBAKKEN LLP Attorneys fo }|l f n fiff

f3sa C. Solbakken, Esq. Robert C. Angelillo, Esq. 750 Lexington Avenue, 25th Floor New York, New York 10022 Tel: (212) 333-0200 Fax: (212)333-2350