郭文贵刑事案 · EXHIBIT · ECF #312-2

元数据

当事人: 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
法院: SDNY
案号: 23-cr-00118
ECF #: 312
类型: EXHIBIT
立案日: 2024-04-30

原始法庭文件为英文，下方为英文全文。

全文

# **EXHIBIT B**

Ho Wan Kwok - April 6, 2022

| APPEARANCES: | | |------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------| | For the Debtor: | WILLIAM R. BALDIGA, ESQ. BEN SILVERBERG, ESQ. Brown Rudnick, LLP Seven Times Square New York, NY 10036 | | For the U.S. Trustee: | HOLLEY E. CLAIBORN, ESQ. STEVEN MACKEY, ESQ. Office of the U.S. Trustee 150 State Street New Haven, CT 06510 | | For Logan Cheng, Creditor: | JAY MARSHALL WOLMAN, ESQ. Randazza Legal Group 100 Pearl Street, 14th Floor Hartford, CT 06103 | | For Pacific Alliance Asia Opportunity Fund, LP, Creditors: | DAVID V. HARBACH, II, ESQ. O'Melveny & Myers, LLP 1625 I Street NW Washington, DC 20006 | | | STUART SARNOFF, ESQ. MAKENZIE RUSSO O'Melveny & Myers, LLP Times Square Tower 7 Times Square New York, NY 10036 | | | ANNECCA SMITH, ESQ. Robinson and Cole 280 Trumbull Street Hartford, CT 06103 | | For Bruno Wu, Weican Meng and Rui Ma, Creditors: | KRISTEN MAYHEW, ESQ. McElroy, Deutsch, Mulvaney & Carpenter One State Street Hartford, CT 06103 | | For the Official Committee of Unsecured Creditors: | STEVEN STAFSTROM, ESQ. Pullman & Comley 850 Main Street Bridgeport, CT 06601 |

Ho Wan Kwok - April 6, 2022 - 1, 1

| 1 | MS. CLAIBORN: Good morning. Today is | |----|------------------------------------------------------| | 2 | Wednesday, April 6th, 2022. We are gathered for the | | 3 | continued meeting of creditors in the Chapter 11 | | 4 | case of Ho Wan Kwok, case no. 22-50073. | | 5 | My name is Holley Claiborn. I'm a trial | | 6 | attorney in the Office of the United States Trustee | | 7 | and I will be conducting today's meeting. Today's | | 8 | meeting is being recorded on a digital recorder and | | 9 | is also available for parties to participate on the | | 10 | phone. And there are parties, including the debtor | | 11 | and counsel and other professionals, gathered here | | 12 | in person. | | 13 | Today's meeting is being interpreted, as | | 14 | you can hear and our interpreter today is Jeff and | | 15 | I'm going to ask Jeff to respond to this oath. | | 16 | (The interpreter is sworn.) | | 17 | THE COURT: On behalf of Mr. Kwok we have | | 18 | William Baldiga and Ben Silverberg. | | 19 | Also on behalf of the debtor we have | | 20 | financial professionals Craig Gelbert and Matthew | | 21 | Flynn. | | 22 | Present here today on behalf of the | | 23 | Committee of Unsecured Creditors is Steven Stafstrom | | 24 | from Pullman and Comley. | | 1 | Mr. Stafstrom is the lawyer for the | | 2 | Official Committee of Unsecured Creditors. | | 3 | Also present today on behalf of PAACS | | 4 | Stuart Sarnoff, David Harbach and MacKenzie Russo. | | 5 | They represent PAACS. | | 6 | On behalf of certain creditors, including | | 7 | Rui Ma, we have Kristen Mayhew. | | 8 | On behalf of creditor, Logan Cheng, we | | 9 | have Jay Wolman. | | 10 | Also on behalf of PAACS we have Annecca | | 11 | Smith, from Robinson and Cole. | | 12 | And then also for the debtor today we have | | 13 | Josh Klein and Aaron Mitchell. | | 14 | Today's meeting will feature me asking | | 15 | questions first, followed by the opportunity for | | 16 | creditors to come up and ask questions. | | 17 | Is anyone on the telephone conference | | 18 | line? | | 19 | MR. MACKEY: Steven Mackey from the U.S. | | 20 | Trustee's Office is on the conference line. | | 21 | Thank you, Mr. Mackey. Anyone else | | 22 | besides Mr. Mackey. | | 23 | Hearing none, I'm going to proceed to | | 24 | swearing in Mr. Kwok. | | 25 | (The debtor is sworn.) |

Fiore Reporting and Transcription Service, Inc.

ന

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 1 MS. CLAIBORN: Mr. Kwok, as you know, 2 today's meeting is being recorded and Mr. Jeff here is our official interpreter for today. 3 4 Jeff will be interpreting the questions റ that I ask and your answers, and I ask that you wait 6 until Jeff has made a full translation before you 7 answer my questions. 8 EXAMINATION BY MS. CLAIBORN: ੇ Q Mr. Kwok, we're going to pick up today in 10 an area that we left off in general from the last meeting of creditors that was held back on March 11 . 12 21st, 2022. 13 Has anything changed in your employment 14 status since March 21st, 2022? 15 A No . 16 o Has anything changed with respect to your 17 residence? the subscription of the states of the states 18 A No . 19 റു During the meeting held on March 21st, 20 2022 I asked you about the accuracy of your 21 bankruptcy schedules and your bankruptcy statement 22 of financial affairs. 23 A No change. 24 ್ತಾ Thank you. 25 MS. CLAIBORN: Jeff, for purposes of my

| Ho Wan Kwok - April 6, 2022 | 6 | |-----------------------------|------------------------------------------------------| | 1 | questions I'm going to be following the documents | | 2 | that are in front of you. When I say schedules, it's | | 3 | this document. And then this document is the | | 4 | statement of financial affairs. Okay? And when I | | 5 | refer to an ECF number, it's at the top of the page. | | 6 | THE OFFICIAL INTERPRETER: ECF number. | | 7 | Okay. | | 8 | MS. CLAIBORN: Okay? That should allow | | 9 | you to follow along and start on this page. | | 10 | EXAMINATION BY MS. CLAIBORN: | | 11 | Q Okay. Mr. Kwok, I'm going to ask you to | | 12 | make sure you have in front of you, which you appear | | 13 | to do, Schedules A-B through J. | | 14 | THE PRIVATE INTERPRETER: He has Mandarin | | 15 | translations in front of him. | | 16 | BY MS. CLAIBORN: | | 17 | Q I see that Mr. Baldiga, who is seated next | | 18 | to you, has English versions. But in front of you, | | 19 | Mr. Kwok, appear to be translations. Is that | | 20 | accurate? | | 21 | A Just on Schedule A-B. | | 22 | Q Okay. So, Mr. Kwok, when you're answering | | 23 | my questions today, you're going to be taking a look | | 24 | at your own translated versions of the bankruptcy | | 25 | schedules. |

Case 1:23-cr-00118

23-cr-00118-AT Doc

Ho Wan Kwok - April 6, 2022 7

A Okay.

Q Okay.

THE PRIVATE INTERPRETER: Just a minute, Your Honor.

MS. CLAIBORN: Yes.

THE PRIVATE INTERPRETER: I'm having a little difficulty hearing the interpreter when he interprets the witness's answers.

MS. CLAIBORN: Okay. So, Jack, if you could speak up. I'm going to move the microphone.

THE OFFICIAL INTERPRETER: Oh, okay.

MS. CLAIBORN: See if that works.

BY MS. CLAIBORN:

Q Okay. Mr. Kwok, starting at Question No. 1 on Schedule A-B. With respect to Schedule A-B at Question No. 1, that asks if you own any legal or equitable interest in any real estate residence or building or similar property. Your answer to that Question No. 1 was no, Mr. Kwok. Is that an accurate answer?

A Yes.

Q Mr. Kwok, have you owned any real estate between the year 2018 and your bankruptcy filing in February of 2022?

THE OFFICIAL INTERPRETER: Can you repeat

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 8 1 that one? 2 BY MS. CLAIBORN: ო Have you owned any real estate between the o যা year 2018 and your bankruptcy filing in February ഗ 2022? THE OFFICIAL INTERPRETER: Can you repeat e that one? He said he didn't hear that. 7 -ങ BY MS. CLAIBORN: ் Mr. Kwok --റ്റ 10 MR. BALDIGA: I'm sorry. I couldn't hear. THE OFFICIAL INTERPRETER: He said that he 11 didn't understand the translation. I just want to 12 13 make sure I understand first. MS. CLAIBORN: I'll repeat the question. 14 THE OFFICIAL INTERPRETER: Yes. 15 BY MS. CLAIBORN: 16 17 Mr. Kwok, have you owned any real estate between 2018 and February of 2022? 18 19 A No . Mr. Kwok, as of the bankruptcy filing in 20 o February 2022, did you have any equitable interest 21 in any real estate anywhere in the world? 22 | 23 A No . Mr. Kwok, as of the bankruptcy filing in 24 ੈ 25

| | Ho Wan Kwok - April 6, 2022 | |----|------------------------------------------------------| | 1 | any real estate anywhere in the world? | | 2 | A No. | | 3 | Q Mr. Kwok, have you ever owned any real | | 4 | estate in Hong Kong? | | 5 | A No. | | 6 | THE PRIVATE INTERPRETER: What was the | | 7 | answer? | | 8 | THE OFFICIAL INTERPRETER: No. | | 9 | BY MS. CLAIBORN: | | 10 | Q Mr. Kwok, have you ever owned the property | | 11 | located at 16A South Bay Road, Hong Kong? | | 12 | A No. | | 13 | Q Mr. Kwok, do you currently own an | | 14 | apartment at the Sherry Netherland in New York City? | | 15 | THE OFFICIAL INTERPRETER: I didn't get | | 16 | it. Can I ask him repeat the -- repeat the answer? | | 17 | MR. BALDIGA: You have to say -- whatever | | 18 | you're going to say, you have to -- you're talking | | 19 | to everybody, not just Holley, so I need to hear | | 20 | what you're saying. | | 21 | THE OFFICIAL INTERPRETER: Okay. I just - | | 22 | - I just want to ask him to repeat -- repeat the | | 23 | answer. | | 24 | MR. BALDIGA: Okay. | | 25 | THE OFFICIAL INTERPRETER: Okay? | | | Ho Wan Kwok - April 6, 2022 10 | | 1 | THE WITNESS: I don't own that real estate | | 2 | in New York, the Sharon -- the Sharons -- at that | | 3 | address I don't remember, and I own -- I own 50 | | 4 | percent the stock -- the stock and -- | | 5 | THE PRIVATE INTERPRETER: No. | | 6 | THE OFFICIAL INTERPRETER: No? | | 7 | THE PRIVATE INTERPRETER: No. | | 8 | THE OFFICIAL INTERPRETER: Okay. | | 9 | THE WITNESS: For the family. | | 10 | MS. CLAIBORN: Can I ask you not to | | 11 | interrupt? Can you just wait until the end and then | | 12 | -- | | 13 | THE PRIVATE INTERPRETER: Okay. | | 14 | MS. CLAIBORN: -- you can express whatever | | 15 | it is you want to say? | | 16 | THE PRIVATE INTERPRETER: Okay. | | 17 | MS. CLAIBORN: Can you please just | | 18 | translate Mr. Kwok's answer again? | | 19 | THE OFFICIAL INTERPRETER: Yeah. I just | | 20 | want to repeat, make sure -- and I said it right, | | 21 | you know, what he said. | | 22 | THE WITNESS: So, yeah, he -- he said, I | | 23 | owe -- I own 50 percent of the -- 50 percent, but I | | 24 | don't own the whole real estate, but I just | | 25 | represent the family. | | | Ho Wan Kwok - April 6, 2022 11 | | 1 | BY MS. CLAIBORN: | | 2 | Q Mr. Kwok, what do you own 50 percent of? | | 3 | A Bravo Luck, 50 percent of the stock powder | | 4 | -- power. I don't know. I don't understand. | | 5 | THE PRIVATE INTERPRETER: (Indiscernible.) | | 6 | THE OFFICIAL INTERPRETER: He owned -- he | | 7 | said he owns the 50 percent of it. | | 8 | THE PRIVATE INTERPRETER: -- we can hear | | 9 | you fine, Holley. | | 10 | MS. CLAIBORN: Okay. I'm going to ask -- | | 11 | I'm going to -- | | 12 | THE PRIVATE INTERPRETER: I don't know if | | 13 | the microphone is connected to anything. | | 14 | MS. CLAIBORN: It is. It is. Jeff, if | | 15 | you can speak up? | | 16 | THE OFFICIAL INTERPRETER: Mr. Kwok said | | 17 | he owe -- he owns 50 percent of -- of the stock. Is | | 18 | it like the stock of the real estate or something? | | 19 | I don't know. I don't get it. But you can help if | | 20 | she wants to help. Do you want him to help a little | | 21 | bit? | | 22 | MS. CLAIBORN: I'd rather not. | | 23 | THE OFFICIAL INTERPRETER: Okay. | | 24 | MS. CLAIBORN: So, I'll just -- I'll ask | | 25 | follow-up questions. |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 12 THE OFFICIAL INTERPRETER: Okay. 1 MR. BALDIGA: All right. But I need to 2 hear if it's a misinterpretation, so --3 MS. CLAIBORN: I'm going to ask a 4 clarifying question, if I could. ടു 6 BY MS. CLAIBORN: Mr. Kwok, do you own 50 percent of a 7 ു ထ company called Bravo Luck? I represent my family to hold 50 percent ਨੇ A 10 of the stock. Mr. Kwok, when you use the term --11 ു MR. BALDIGA: Could I hear that back? 12 13 Could you repeat that? THE OFFICIAL INTERPRETER: Yeah. I 14 represent my family to hold 50 percent of the stock 15 of the -- of the company. 16 17 MR. BALDIGA: Okay. 18 BY MS. CLAIBORN: 19 o Mr. Kwok, when you say family, what do you 20 mean? My family is a big family and that 21 A 22 | includes a lot of people. My kids and my sister-inlaws, and all people together. A lot of people. 23 1 24 Mr. Kwok, who owns an interest --റ്റ MR. BALDIGA: Excuse me. We do have an 25

| | Ho Wan Kwok - April 6, 2022 13 | |----|------------------------------------------------------| | | interpretation question. | | | THE PRIVATE INTERPRETER: I just want to | | | ask that, is there supposed to be summary of the | | 4 | (indiscernible) the interpretation? | | 5 | MS. CLAIBORN: To the best of Mr. Jeff's | | ు | ability, it should be verbatim. | | 7 | THE PRIVATE INTERPRETER: Right. So if | | ರು | Mr. Kwok said, my son, my daughter, my brother, my | | න | sister-in-law, my nephew, my niece, many people, | | 10 | then if the interpreter say, well, a lot of my | | 11 | families and my brother, many people, then should it | | 12 | be correct or not? | | 13 | MS. CLAIBORN: I would prefer that Mr. | | 14 | Jeff translate as literally as possible. So with | | 15 | that instruction, can we -- | | 16 | THE OFFICIAL INTERPRETER: Yeah. | | 17 | MS. CLAIBORN: -- do a specific job as | | 18 | best we can going forward? Thank you. | | 19 | MR. BALDIGA: Thank you. | | 20 | BY MS. CLAIBORN: | | 21 | ੁ So, Mr. Kwok, who owns the company called | | 22 | Bravo Luck? | | 23 | ದ My son. | | 24 | ೧ And what is your son's name? | | 25 | A Cheng Wu. |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 14 1 How long has your son owned Bravo Luck? 0 2 Д I don't remember. 3 THE PRIVATE INTERPRETER: Say again, 4 please. THE OFFICIAL INTERPRETER: I don't 5 ട remember. 7 BY MS. CLAIBORN: ထ Q So, Mr. Kwok, what do you own 50 percent of when you explained your ownership interest in the 10 Southern Sherry Netherland? MR. BALDIGA: Objection. You may 11 12 interpret. THE OFFICIAL INTERPRETER: Can you repeat 13 14 that one again, Holley? 15 BY MS. CLAIBORN: 16 o Mr. Kwok, you testified that you owned 50 percent of some company, and that was in response to 17 my question if you owned the Sherry Netherland 18 apartment. Can you please explain what you meant? 19 -20 A Sherry is a co-op. It doesn't have the --21 it doesn't have the -- it doesn't have the 22 ownership. 23 THE PRIVATE INTERPRETER: May I, Ms. 24 Holley? 25 MR. BALDIGA: Yes, of course.

Ho Wan Kwok - April 6, 2022 15

THE PRIVATE INTERPRETER: You've got to speak louder. MS. CLAIBORN: Okay. I'm going to put ourselves on pause for a second here. (Off the record) MS. CLAIBORN: All right. We're back on the record after a short break, and Mr. Kwok, you remain under oath. Jeff, could you please retranslate? THE OFFICIAL INTERPRETER: Yeah. MS. CLAIBORN: The last question. You want me to ask it again? THE OFFICIAL INTERPRETER: Yeah. Would you ask it again? MS. CLAIBORN: All right. I'll try it again. BY MS. CLAIBORN: Q Mr. Kwok, you testified today that you own 50 percent of an interest in some company, and that was the answer you gave me in response to my question if you own an apartment at the Sherry Netherland. Can you please explain your answer? MR. BALDIGA: Objection. THE WITNESS: I don't know how to explain it. He said the Sherry Netherland is a co-op. I

Fiore Reporting and Transcription Service, Inc.

| | Ho Wan Kwok - April 6, 2022 16 | |----|------------------------------------------------------| | 1 | don't have a deed on that property and I just | | 2 | represent my family to own 50 percent of the right. | | 3 | MR. BALDIGA: Excuse me. Go ahead. | | 4 | THE PRIVATE INTERPRETER: Because that -- | | 5 | Mr. Kwok did mention the company name Bravo Luck, so | | 6 | Mr. Interpreter did not say the word Bravo Luck, the | | 7 | company that holds the interest of Sherry | | 8 | Netherland, and Mr. Kwok represents the family owns | | 9 | 50 percent of Bravo Luck, which is the holding | | 10 | company of owning the Sherry Netherland. The Sherry | | 11 | Netherland is a co-op. | | 12 | MR. BALDIGA: So I'm going to make a | | 13 | continuing objection to the extent that the | | 14 | interpreter is not providing the exact words used by | | 15 | the witness. I'm not ascribing any faults or | | 16 | anything, but obviously that's critical to the | | 17 | quality of the testimony and that's necessary. | | 18 | MS. CLAIBORN: We need -- | | 19 | MR. BALDIGA: We have to use the words | | 20 | used by the witness. | | 21 | MS. CLAIBORN: I'm sure that Jeff is going | | 22 | to do his best job today to try to translate | | 23 | everything literally. | | 24 | MR. BALDIGA: Thank you. | | 25 | MS. CLAIBORN: But please understand that |

ed 04/30/24 Pac

Ho Wan Kwok -- April 6, 2022

there is a familiarity with terms in this room that Mr. Jeff does not have. So to the extent that people are answering questions with shorthand versions of company names or just one words, the answer should be as specific as possible -- THE OFFICIAL INTERPRETER: Yeah, I -- MS. CLAIBORN: -- if you could translate that. THE OFFICIAL INTERPRETER: -- my best but probably that interpreter honestly, Holley, the interpreter probably know the case more, the details. MS. CLAIBORN: I agree. Can you just -- THE OFFICIAL INTERPRETER: But if he -- MS. CLAIBORN: -- can you translate what I

## just said to Mr. Kwok, because I want to make sure

THE OFFICIAL INTERPRETER: Oh. MS. CLAIBORN: -- he answers questions in a way that are easily translatable. THE OFFICIAL INTERPRETER: I just tell him and the answer let -- you know short and clear, but I pretty much understand what he says and -- MS. CLAIBORN: And can you please translate Mr. Kwok's answers or comments to your

Fiore Reporting and Transcription Service, Inc.

| 1 | comments? | |------|-------------------------------------------------------------------------------------------| | 2 | THE OFFICIAL INTERPRETER: He said he will | | 3 | try to make it a shorter and clear and -- but he | | 4 | needs to explain the details as much as he can | | 5 | because it's a -- it's related to his lifeline. | | 6 | MS. CLAIBORN: Mr. Sarnoff? | | 7 | MR. SARNOFF: Yeah. I just wanted to make | | 8 | clear that to the extent there is a discrepancy | | 9 | between the interpreter -- the translator, the | | 10 | official translator and Mr. Kwok's interpreter, that | | 11 | the translator is the final arbiter and that unless | | 12 | the translator agrees with the translation | | 13 | difference that the interpreter is putting forth, | | 14 | they have to work that out before we can defer to | | 15 | the -- to Mr. Kwok's personal interpreter as what | | 16 | Mr. Kwok said. | | 17 | MR. BALDIGA: I don't accept that. | | 18 | MR. SARNOFF: That's fine. | | 19 | MR. BALDIGA: That can be your position. | | 20 | MR. SARNOFF: Okay. The position has to | | 21 | be that the translator has to agree with the | | 22 | interpreter about what Mr. Kwok said for the record | | 23 | to be accurate. | | 24 | MR. BALDIGA: That -- I understand your | | 25 | position. | | 1 | THE OFFICIAL INTERPRETER: So, Holley, if | | 2 | I miss anything that his personal interpreter wants | | 3 | to make up whatever I'm missing, some of the detail | | 4 | information, and is it okay for her to add on and if | | 5 | I agree what -- you know, what I'm missing or what | | 6 | he said, maybe I'm missing some detail information | | 7 | and some -- | | 8 | MS. CLAIBORN: I think the better route | | 9 | for today -- | | 10 | THE OFFICIAL INTERPRETER: Yeah. | | 11 | MS. CLAIBORN: -- and for purposes of a | | 12 | clear translation and a clear record -- | | 13 | THE OFFICIAL INTERPRETER: Okay. | | 14 | MS. CLAIBORN: -- is for you, Jeff, to | | 15 | interpret | | 16 | THE OFFICIAL INTERPRETER: Uh-huh. | | 17 | MS. CLAIBORN: -- my questions and to | | 18 | interpret Mr. Kwok's answers. | | 19 | THE OFFICIAL INTERPRETER: Okay. | | 20 | MS. CLAIBORN: And if Mr. Kwok thinks, | | 21 | based on your interpretation, that you have not | | 22 | translated properly, then he can testify again and | | 23 | you can try again. | | 24 | But I would like to restrict the | | 25 | interaction that happens between translators and | | | 227 88 88 84 66 88 88 88 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 60 60 600 600 600 Car V | | । | between Mr. Kwok's personal translator so that we | | 2 | have an official record where the person asking the | | 3 | question is me, it's being officially translated, | | ್ನೆ | and Mr. Kwok is giving the answers, and that also is | | 5 | being officially translated. | | 6 | MR. BALDIGA: But, Holley, the problem | | 7 | with that is the witness doesn't know whether Jeff's | | 8 | English report is in fact accurate. You can't leave | | 9 | it up to the witness. That's why we have a check | | 10 | interpreter. If he spoke English, then we wouldn't | | 11 | need any interpreters. He can't do that. | | 12 | MS. CLAIBORN: I think as a practical | | 13 | matter, Mr. Kwok speaks enough English to know | | ી વૈ | whether or not he's answered his question. | | 15 | MR. BALDIGA: No, he doesn't. I object. | | 16 | MS. CLAIBORN: Well, I -- I think that | | 17 | that has been what I have seen from my own personal | | 18 | experience. | | । ਉ | That said, we're going to try and do the | | 20 | best we can -- | | 21 | MR. BALDIGA: I agree. | | 22 | MS. CLAIBORN: -- and we'll see where we | | 23 | go . | | 24 | MR. BALDIGA: Okay. | | 25 | Okay? MS. CLAIBORN: |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 21

BY MS. CLAIBORN: Q So back to questions and answers. Mr. Kwok, do you own an interest in Genever Holdings Corporation? A I just have -- in reality, I don't, but I just held -- I just represent my family to hold some interest. Q Is anyone authorized to act on behalf of Genever Holdings Corporation aside from you? A My son. Q Is there a document that memorializes your ownership interest, whatever it is, in Genever Holdings Corporation? MR. BALDIGA: Objection. You -- you may answer. THE WITNESS: No. THE PRIVATE INTERPRETER: Ms. Holley, can I -- first of all, the last time that -- when he was saying -- instructing the witness about his testimony, what should it be, I don't think the interpreter -- the official interpreter interpreted your instruction. He is telling the witness what he should be doing, but not what you were saying. And then, now that the witness is saying that he asked the interpreter twice that -- you were

Fiore Reporting and Transcription Service, Inc.

| | Ho Wan Kwok - April 6, 2022 22 | |----|-----------------------------------------------------| | 1 | talking about ownership, you were talking about | | 2 | ownership interest. Now he used twice these words, | | 3 | and then at the end, Mr. Jeff said, yes. And then, | | 4 | so he answered no, but then the interaction was not | | 5 | interpreted. | | 6 | MS. CLAIBORN: Mr. Jeff, could you | | 7 | translate? | | 8 | THE OFFICIAL INTERPRETER: I don't know | | 9 | what she just said. I don't know. I didn't | | 10 | understand what she's saying. | | 11 | THE PRIVATE INTERPRETER: I mean, every | | 12 | word should be interpreted. The witness -- every | | 13 | word the witness says should be interpreted. Ms. | | 14 | Holley's words should be interpreted, right? | | 15 | MS. CLAIBORN: Yes. | | 16 | THE PRIVATE INTERPRETER: Right. But he | | 17 | will -- not interpreted Ms. Holley's -- and you did | | 18 | not interpret everything Mr. Kwok said. | | 19 | THE OFFICIAL INTERPRETER: Okay. Maybe -- | | 20 | maybe we should have her to interpret. I'm going to | | 21 | excuse myself. I don't know -- | | 22 | MS. CLAIBORN: I'm going to put the -- | | 23 | THE OFFICIAL INTERPRETER: -- I'm not | | 24 | familiar with -- | | 25 | MS. CLAIBORN: -- I'm going to put the |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 23

matter on pause for a moment.

THE OFFICIAL INTERPRETER: Yeah, yeah, yeah.

(Off the record)

MS. CLAIBORN: All right. We are back on the record after a short break.

Mr. Kwok, you remain under oath.

BY MS. CLAIBORN:

Q Mr. Kwok, do you have any United States currency with you today?

A No.

Q When you filed your bankruptcy case, did you have any United States currency?

A No.

Q Mr. Kwok, do you own any foreign currency?

A No.

Q Mr. Kwok, do you own any digital currency?

A No.

Q Mr. Kwok, do you have any financial accounts of any kind in the United States?

A No.

Q Mr. Kwok, do you have any financial accounts of any kind outside of the United States?

A No.

Q On March 21st, you testified you have no

Fiore Reporting and Transcription Service, Inc.

| Ho Wan Kwok - April 6, 2022 | | |-----------------------------|------------------------------------------------| | 1 | job and no source of income. Who pays for your | | 2 | household expenses? | | 3 | A Sometimes my son, sometimes my wife, or | | 4 | sometimes my other family member. | | 5 | Q Do you have access to any credit cards? | | 6 | A No. | | 7 | Q Do you have access to any debit cards | | 8 | attached to a bank account? | | 9 | A No. | | 10 | Q How do you pay for groceries? | | 11 | A My son, my wife, my family members' | | 12 | company pay for. | | 13 | Q Where does your son live? | | 14 | A London. | | 15 | Q How does your son send you money? | | 16 | A He has a family office in a company, New | | 17 | York. | | 18 | Q Does the family office give you money? | | 19 | A They pay the expenses above. | | 20 | Q What does the term family office mean? | | 21 | MR. BALDIGA: Objection. You may answer. | | 22 | THE OFFICIAL INTERPRETER: Can I ask to -- | | 23 | ask him to repeat? | | 24 | MS. CLAIBORN: Yes. | | 25 | THE OFFICIAL INTERPRETER: Okay. Can you |

Ho Wan Kwok - April 6, 2022 25

-- MR. BALDIGA: Right. He also have to interpret for the witness what I say. MS. CLAIBORN: You haven't said anything yet and he's going to ask him to repeat his answers so then he's going to translate, and then we can have whatever discussion you want to have. THE PRIVATE INTERPRETER: The counsel raised objection. The interpreter did not interpret the objection. MS. CLAIBORN: I can happily repeat the question, but we are not going to get anywhere today in a meaningful fashion if people are interrupting on basic questions.

## MR. BALDIGA: No, I didn't interrupt, but

MS. CLAIBORN: So let me try again. MR. BALDIGA: Okay. But hold on. If I object or if I say anything else, that has to be interpreted. MS. CLAIBORN: You're not waiting for space to interpret. So, Mr. Jeff, can you interpret that exchange that just happened? THE OFFICIAL INTERPRETER: Okay. I don't know. It's just too much interruption.

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 26 1 MS. CLAIBORN: Right. 2 THE OFFICIAL INTERPRETER: Holley, I can't do -- keep doing this. I just too distracted and I 3 don't know. It just a simple -- ask the witness বা 5 just a simple repeat and then --6 MS. CLAIBORN: Let me try --THE OFFICIAL INTERPRETER: --- it gets all 7 8 these people involved. MS. CLAIBORN: Correct. Let me -- ਉ 10 THE OFFICIAL INTERPRETER: We're not going 11 anywhere. 12 MS. CLAIBORN: Let me try the question 13 again. 14 BY MS. CLAIBORN: Q Mr. Kwok, what do you mean by the term, 15 16 family office? MR. BALDIGA: Objection. You may answer. 17 MS. CLAIBORN: Mr. Baldiga, that term is 18 all over the papers. Can you repeat -- translate? 19 -20 THE OFFICIAL INTERPRETER: No, I'm not going anywhere. Holley, I just excuse myself. I'm 21 22 1 sorry. It's -- it's not going --23 MS. CLAIBORN: I'm going to put it on 24 pause, please. THE OFFICIAL INTERPRETER: -- this is too 25

Ho Wan Kwok - April 6, 2022 27

much. (Off the record) MS. CLAIBORN: We're back on the record after a short break. Mr. Kwok, you remain under oath. During the break, I spoke with Attorney Baldiga and we have agreed that all objections as to form of the question are reserved. I'm going to go back to my questions. BY MS. CLAIBORN: Q The question we left off after the break was what do you mean by the term family office? A They are representing my big family. It's a company my son, my daughter, my wife, and it's a company representing my family for investment. Q What is the name of the company? A Golden Spring Europe. Q Do you mean Golden Spring New York? A Roughly the name. Q Who pays for the meals that you eat? A Sometimes my wife's company, sometimes my family office, my son's company. Q Mr. Kwok, when you use the term family office, are you referring to the company known as Golden Spring New York Limited?

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 28 THE OFFICIAL INTERPRETER: What's the name 1 2 of the company? Can I -- can you repeat it? 3 MS. CLAIBORN: The name is Golden Spring বা New York Limited. 5 THE WITNESS: Yes . 6 BY MS. CLAIBORN: 7 In your bankruptcy case, you filed a Q ထ report covering your expenses for the month of ி February. 10 THE OFFICIAL INTERPRETER: May I repeat 11 again? 12 MS. CLAIBORN: Maybe I'll try it again. THE OFFICIAL INTERPRETER: Thank you. 13 14 BY MS. CLAIBORN: 15 Mr. Kwok, you filed a monthly operating report covering the month of February 2022, and that 16 report shows you spent approximately \$160,000. 17 MR. BALDIGA: Objection. I object. 18 19 BY MS. CLAIBORN: 20 o Who funded the disbursements of \$160,000? 21 Some from the Golden Spring family office A 22 1 and the company, some were paid by my wife and my 23 wife's company. 24 o What is the name of your wife's company? 25 A Greenwich, in Connecticut.

Case 1:23-cr-001

| Ho Wan Kwok - April 6, 2022 29 | | |-------------------------------------------------------------------|-----------------------------------------------------| | 1 | Q Are you referring to the company? | | 2 | A Yes, the company name. | | 3 | Q What expenses does your wife company, | | 4 | Greenwich, pay for? | | 5 | A Mostly food, because I live in my wife's | | 6 | house. We share the cleaning, the expenses because | | 7 | -- and also the garden maintenance expenses. | | 8 | UNIDENTIFIED SPEAKER: Okay. Can we take | | 9 | a quick time out so I can speak with my co-counsel? | | 10 | Or with my partner. | | 11 | MR. BALDIGA: No, let's just wait. | | 12 | BY MS. CLAIBORN: | | 13 | Q Where does your wife's company, Greenwich, | | 14 | get its money from? | | 15 | A I don't know. | | 16 | Q Did your wife's company, Greenwich, pay | | 17 | for any professional expenses? | | 18 | A I don't know. | | 19 | Q Is your wife the person who actually makes | | 20 | the payments? | | 21 | A Yes. | | 22 | Q Does your wife have a checking account? | | 23 | A I don't know. | | 24 | Q Does your wife have a debit card? | | 25 | A I don't know. |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 30 1 When you eat in a restaurant with your O 2 wife, who pays the bill? I never went to a restaurant with my wife. 3 A ರ್ ರ Q Ever? I think I was chased by these people and I ഹ A 6 | never went. Thinks I -- you know, I think I was 7 chased by these people. 8 Q Does your wife buy groceries? ி A Sometimes. 10 ್ How does she pay for them? A I don't know. 11 Why does Golden Spring New York pay for 12 റ്റ 13 some of your personal expenses? Because I'm one of the family member, and 14 A my son is very successful and he loves me very much. 15 Is there any other reason? 16 ರ I don't know. 17 A What personal living expenses of yours 18 ੁ 19 does Golden Spring pay for? 20 A The expense from security because I was chased by the people in the back, and the 21 transportation, clothing, and some items for living. 22 -23 Q Who is the person at Golden Spring New 24 York --MS. CLAIBORN: Wait a minute. I'm going 25

| Ho Wan Kwok - April 6, 2022 31 | | |--------------------------------|--------------------------------------------------| | 1 | to ask a full question. | | 2 | BY MS. CLAIBORN: | | 3 | Q So who is the person at Golden Spring New | | 4 | York who authorizes the payment of your personal | | 5 | living expenses? | | 6 | A My son. | | 7 | Q Please explain how your son authorizes | | 8 | those payments. | | 9 | A I usually communicate with Golden Spring, | | 10 | the company's manager and CEO. | | 11 | THE PRIVATE INTERPRETER: (Indiscernible) | | 12 | director, not manager. | | 13 | THE OFFICIAL INTERPRETER: Could you -- | | 14 | okay. Director, not a manager. | | 15 | MR. BALDIGA: Thank you. | | 16 | BY MS. CLAIBORN: | | 17 | Q Mr. Kwok, who is the director or manager | | 18 | that you just referred to? | | 19 | A Wang Yanping. | | 20 | Q Is Ms. Ping a officer of Golden Spring New | | 21 | York? | | 22 | A She is a Miss. She's a lady. | | 23 | Q Is Ms. Ping a corporate officer of Golden | | 24 | Spring New York? | | 25 | A Yes. Yes. Co. |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 32 1 What is her title? ೧ 2 A She is a officer or director. က റ്റ Does she have a position title? ব A I don't know. 5 Mr. Kwok, are you a corporate officer of റ ଚ Golden Spring New York? 7 A Now? 8 Q Yes . ਹੈ A No . Mr. Kwok, have you ever been in the past, 10 Q a corporate officer of Golden Spring New York? 11 12 A I seem to hold a title when the company 13 | was established in 2015. I forgot what title was it 14 then. 15 Q Mr. Kwok, do you own any interest in 16 Golden Spring New York? 17 A No . In the past, have you ever had any kind of 18 ੋ 19 | ownership interest in Golden Spring New York? 20 A No . 21 Were you involved in the formation of ു 22 | Golden Spring New York? 23 A Yes . 24 Q What was your role in the formation of 25 Golden Spring New York?

| Ho Wan Kwok - April 6, 2022 33 | | | |--------------------------------|---|------------------------------------------------------| | 1 | A | Consultant and giving advice, suggestions. | | 2 | Q | Was your son involved in the formation of | | 3 | | Golden Spring New York? | | 4 | A | He is the main person. He -- he was the | | 5 | | main person. | | 6 | Q | When Golden Spring New York was created, | | 7 | | who had the ownership interest in New York -- Golden | | 8 | | New -- Golden Spring New York? | | 9 | A | My son. | | 10 | Q | Did Golden Spring Hong Kong have any | | 11 | | ownership interest in Golden Spring New York? | | 12 | A | I don't know the detail of the interest | | 13 | | and because this -- these two combined, it's | | 14 | | considered one thing. | | 15 | Q | Is Golden Spring Hong Kong a separate | | 16 | | company from Golden Spring New York? | | 17 | A | I don't know. | | 18 | Q | Who owns Golden Spring Hong Kong? | | 19 | A | My son. | | 20 | Q | In 2015, when Golden Spring New York was | | 21 | | formed, who owned Golden Spring Hong Kong? | | 22 | A | I don't know. | | 23 | Q | Are you a corporate officer of Golden | | 24 | | Spring Hong Kong? | | 25 | A | I don't remember. |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 Q Have you ever been a cooperate officer of Golden Spring Hong Kong? A I don't remember. Q Do you have any ownership interest in ഗ Golden Spring Hong Kong? A No . Have you ever in the past, had an റ്റ ထ ownership interest in Golden Spring Hong Kong? A No . Q What type of business is Golden Spring New York engaged in? I don't know. A Q How does Golden Spring New York generate revenue? A T don't know. THE PRIVATE INTERPRETER: Ms. Holley, I don't know if this -- the (indiscernible) he said, 18 how does Golden Spring New York generate revenue, 19 | not how does Golden Spring New York making money,

20 right?

ന

ণা

ਰੇ

21 MS. CLAIBORN: That was basically my 22 question. 23 THE PRIVATE INTERPRETER: Yeah, so the 24 interpreter should not say -- interpret it in such a 25 | way that Golden Spring New York -- how does Golden

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 - 11: 35 1 Spring New York make money, to the -- to the -- to 2 Mr. Kwok. 3 THE OFFICIAL INTERPRETER: Generate money, 4 yeah. Generate revenue, generate money. 5 THE PRIVATE INTERPRETER: No, but you said 6 7 MS. CLAIBORN: I'm happy to ask it 8 specifically. ਾ ਹੈ। BY MS. CLAIBORN: 10 Q How does Golden Spring New York make 11 money? 12 A I don't know. 13 Q In the year 2015, were you involved in । বাঁ Golden Spring New York's business? 15 I don't remember. মা 16 Ox Have you ever given a gift of money to 17 Golden Spring New York? 18 A No . 19 Have you ever given any money to Golden 20 Spring New York? 21 : No. " Have you ever transferred any property of 22 23 | any kind to Golden Spring New York? 24 A No . 25 Q Have you ever funded Golden Spring New

Ho Wan Kwok - April 6, 2022 36 1 York in any way? 2 A No . 3 Q Have you ever loaned money to Golden 4 Spring New York? 5 A No . ଚ Q Have you ever invested any of your own 7 money in Golden Spring New York? 8 A No . 9 What corporate position does Yanping Wang ್ತ 10 Hold? Officer and director. 11 A 12 Q Is Yanping Wang the president of Golden 13 Spring New York? । ਪੈ A Yes . 15 Does Golden Spring New York have any other o 16 corporate officers? 17 A Yes . ್ 18 Who are they? I don't remember clearly about their 19 A 20 names. 21 റ്റു Please tell me what you remember. 22 What -- I don't remember their names A 23 clearly and -- because I don't even remember 24 attorney's names. I don't want to misleading you, 25 Holley.

| Ho Wan Kwok - April 6, 2022 37 | | | |--------------------------------|---|------------------------------------------------------| | 1 | Q | How many officers does Golden Spring New | | 2 | | York have? | | 3 | A | I don't remember. Oh, I don't know. | | 4 | | Sorry. I don't know. | | 5 | Q | Does Golden Spring New York have any | | 6 | | directors? | | 7 | A | Yanping Wang. | | 8 | Q | Is Ms. Wang the only director of Golden | | 9 | | Spring New York? | | 10 | A | I don't know. | | 11 | Q | Where does Golden Spring New York get the | | 12 | | money that it uses to pay your personal expenses? | | 13 | A | I don't know. | | 14 | Q | Does Golden Spring New York have any | | 15 | | employees? | | 16 | A | Yes. | | 17 | Q | How many? | | 18 | A | I don't know. | | 19 | Q | Are you currently involved in any way in | | 20 | | the business of Golden Spring New York? | | 21 | A | No. | | 22 | Q | What does Golden Spring New York own? | | 23 | A | I don't know. | | 24 | Q | Golden Spring New York is willing to loan | | 25 | | you the sum of \$8 million. Where is it getting that |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 38 1 \$8 million from? 2 A I don't know. က Are you the person who asked Golden Spring ○ ধ New York to loan you \$8 million? 5 A No . 6 റ്റു Who asked Golden Spring New York to loan 7 you \$8 million? 8 A My attorney. 9 O Which attorney? 10 Aaron Mitchell here. A 11 റ്റ Are you referring to Aaron Mitchell? 12 Now I remember his name now. A UNIDENTIFIED SPEAKER: Just for the 13 14 record, I'm not sure Mr. Mitchell has registered an 15 appearance yet. It would be appropriate if he's going to be here representing the debtor, if he 16 (indiscernible) his appearance. 17 MS. CLAIBORN: I believe I did read Mr. 18 19 1 Mitchell's name earlier today. UNIDENTIFIED SPEAKER: He hasn't filed --20 21 MS. CLAIBORN: He did sign --22 UNIDENTIFIED SPEAKER: -- an appearance in 23 this matter. 24 MS. CLAIBORN: Thank you. Can you 25 translate that?

Ho Wan Kwok - April 6, 2022 39

THE OFFICIAL INTERPRETER: I didn't hear totally clearly. I know it's some distance. I don't --

BY MS. CLAIBORN:

Q Does Golden Spring New York have any bank accounts?

A I don't know.

Q Do you have access to Golden Spring New York's financial accounts?

A No.

Q Do you have authority to enter into financial transactions on behalf of Golden Spring New York?

A No.

THE PRIVATE INTERPRETER: No. No, that's not the question.

THE OFFICIAL INTERPRETER: What was it?

MS. CLAIBORN: I'm happy to repeat the question.

BY MS. CLAIBORN:

Q Do you have authority to enter into financial transactions on behalf of Golden Spring New York? Mr. Kwok, if you don't answer -- if you don't understand my question --

THE OFFICIAL INTERPRETER: He's asking if

Fiore Reporting and Transcription Service, Inc.

| | Ho Wan Kwok - April 6, 2022 40 | |----|-----------------------------------------------------------------| | 1 | he -- if I was asking if he has the right to use the | | 2 | -- the Golden Spring New York, the accounts for | | 3 | transactions. You know. | | 4 | MS. CLAIBORN: That was not my question. | | 5 | BY MS. CLAIBORN: | | 6 | Q Mr. Kwok, are you authorized to enter into | | 7 | any kind of financial transactions on behalf of | | 8 | Golden Spring New York? | | 9 | A No. | | 10 | MR. BALDIGA: Excuse me, the interpreter | | 11 | might have a comment. | | 12 | MS. CLAIBORN: Can you translate that, | | 13 | please? | | 14 | THE OFFICIAL INTERPRETER: Yeah. She said | | 15 | that it's the trading -- trading of the financial | | 16 | trading -- | | 17 | THE PRIVATE INTERPRETER: Transaction. | | 18 | THE OFFICIAL INTERPRETER: -- transaction | | 19 | to -- | | 20 | THE PRIVATE INTERPRETER: Not trading. | | 21 | THE OFFICIAL INTERPRETER: He said that, | | 22 | no, he was not -- I was not authorized to do the | | 23 | transactions, financial transactions. | | 24 | BY MS. CLAIBORN: | | 25 | Q What, if anything, do you currently do for | | | Ho Wan Kwok - April 6, 2022 41 | | 1 | Golden Spring New York? | | 2 | A No. | | 3 | Q Is Golden Spring New York funding your | | 4 | son's personal living expenses? | | 5 | A I don't know. | | 6 | Q Is Golden Spring New York funding your | | 7 | daughter's personal living expenses? | | 8 | A I don't know. | | 9 | Q Do you owe any money to Golden Spring New | | 10 | York? | | 11 | A Yes. | | 12 | Q How much? | | 13 | A Like more than \$21 million. | | 14 | Q How do you owe more than \$21 million to | | 15 | Golden Spring New York? | | 16 | A Because in the past five years and I was | | 17 | sued by a lot of creditors. | | 18 | Q Did Golden Spring New York -- | | 19 | MS. CLAIBORN: I apologize. | | 20 | THE OFFICIAL INTERPRETER: I just ask him | | 21 | to repeat. | | 22 | THE WITNESS: In the past five years, I | | 23 | was chased by Chinese Communist Party. | | 24 | THE OFFICIAL INTERPRETER: I didn't get |

Fiore Reporting and Transcription Service, Inc.

1 time. 2 MR. BALDIGA: Short -- short answer. ന THE WITNESS: In the past five years I was trapped -- trapped by some of the cases from Chinese খা ഗ Communist Party, designed by the Chinese Communist ର Party, including the case past, that case. I need to -- need to pay a large amount of legal fees so 7 -ထ that's why I got the support from the Golden Spring New York. This is the main reason I owe \$21 10 million. 11 THE PRIVATE INTERPRETER: Interpreter 12 missed that, the legal -- legal fee. THE OFFICIAL INTERPRETER: Yeah, I said 13 14 the legal fee. I said that. Did I say legal fee? THE PRIVATE INTERPRETER: I didn't think 15 so, but as long as you say that. 16 17 BY MS. CLAIBORN: How much of the \$21 million is comprised 18 o 19 of legal fees? THE OFFICIAL INTERPRETER: Can you repeat 20 21 that one again? 22 BY MS. CLAIBORN: 23 How much of the \$21 million -o 24 THE OFFICIAL INTERPRETER: Okay. 25 BY MS. CLAIBORN:

Fiore Reporting and Transcription Service, Inc.

Case 1:23-cr-00118-A

| Ho Wan Kwok - April 6, 2022 | |-----------------------------|-- | 1 | Q | 2 | A | 3 | Q | 4 | | 5 | A | 6 | | 7 | | 8 | | 9 | Q | 10 | | 11 | A | 12 | Q | 13 | | 14 | A | 15 | | 16 | Q | 17 | | 18 | A | 19 | | 20 | 21 | 22 | 23 | 24 | 25 | Q | 43 | -----------------------------------------|-----------------------------------------------------| | -- is comprised of legal fees? | | I think most of it is legal fee. | | Why is Golden Spring New York paying your | | legal fees? | | Because the Golden Spring New York is my | | son and my family's company and they love me very | | much. They hope -- they hoping me to live, not be | | killed by the people behind me. | | Do you have any written agreement with | | Golden Spring New York? | | Yes. | | What legal -- sorry. What written | | agreements do you have with Golden Spring New York? | | It's agreement for borrowing -- borrowing | | money. | | When did you enter into that agreement to | | borrow money? | | A few years ago. I know -- I don't know | | rough time. | | THE PRIVATE INTERPRETER: I don't recall. | | | MS. CLAIBORN: What -- | | | THE OFFICIAL INTERPRETER: What -- yeah, I | | | don't remember the time. | | | BY MS. CLAIBORN: | | | What are the terms of the legal agreement |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 44 with Golden Spring New York? Sorry. Let me 1 rephrase that. What are the terms of the written 2 က agreement with Golden Spring New York? ণ A I don't remember. 5 UNIDENTIFIED SPEAKER: Sorry. Could you 6 repeat the English, please? 7 MS. CLAIBORN: Go ahead and say that --8 repeat. THE OFFICIAL INTERPRETER: I don't ੇ 10 remember. BY MS. CLAIBORN: 11 12 Q Are you obligated under that written agreement with Golden Spring New York to pay back 13 14 all of the money? 15 ಗ್ಗೆ Yes . 16 MR. BALDIGA: There's more to the 17 question. BY MS. CLAIBORN: 18 That Golden Spring paid to lawyers on your 19 20 behalf. 21 A Yes . 22 THE PRIVATE INTERPRETER: It was only 23 (indiscernible) of a difference in the interpreting. 24 For example, the interpreter did not interpret under 25 | the agreement, are you obligated to make them all --

| | Ho Wan Kwok - April 6, 2022 45 | |----|---------------------------------------------------| | 1 | to pay back all the money. All the money that is, | | 2 | you know -- | | 3 | MR. BALDIGA: Okay. | | 4 | THE PRIVATE INTERPRETER: -- spent on the | | 5 | lawyer. | | 6 | MR. BALDIGA: Maybe Holley can clarify | | 7 | that. | | 8 | THE PRIVATE INTERPRETER: Yeah. | | 9 | BY MS. CLAIBORN: | | 10 | Q I'm going to ask a long question. I'm | | 11 | going to break it into parts. | | 12 | Mr. Kwok, are you obligated to pay back | | 13 | Golden Spring New York for all of the money that | | 14 | Golden Spring New York paid to lawyers on your | | 15 | behalf? | | 16 | A Yes. | | 17 | Q Is that agreement with Golden Spring New | | 18 | York in writing? | | 19 | A Yes. | | 20 | Q Is that the same written agreement you | | 21 | mentioned a few minutes ago? | | 22 | A Yes. | | 23 | Q Do you have more than one written | | 24 | agreement with Golden Spring New York? | | 25 | A Yes. |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 4 6 1 What are your other written agreements ் 2 with Golden Spring New York? 3 In the past week, I had a case with Logan A Cheng. The settlement with Logan Cheng, the money বা from -- for the settlement is the money I borrow 6 from Golden Spring New York. 7 Do you have any other written agreements ্র 8 with Golden Spring New York? 9 A I don't remember, 10 Does Golden Spring New York have a fee Q 11 agreement with any of the attorneys who represent 12 you in litigation? 13 Can you -- can you answer, Mr. Kwok? 14 THE OFFICIAL INTERPRETER: Any agreement 15 with -- can you repeat one more time? BY MS. CLAIBORN: 16 Does Golden Spring New York have a -- any 17 o 18 kind of a fee agreement with any of the lawyers who 19 represent Mr. Kwok in litigation? 20 A T don't know. 21 Mr. Kwok, who represents you in the Q 22 | litigation you filed against UBS in London? 23 A Attorney -- attorney office in London. 24 ್ What is the name? I don't remember completely about the 25 A

Ho Wan Kwok - April 6, 2022 47

English name.

Q Does Golden Spring New York have a fee agreement with that attorney in London?

A There should be.

MR. BALDIGA: I'm sorry. What was the answer?

THE OFFICIAL INTERPRETER: Should have.

BY MS. CLAIBORN:

Q Do you know if it does have enough -- have a fee agreement?

A I'm not sure.

Q Who is the person at Golden Spring New York who authorized payment of your litigation expenses?

A My son.

Q Does your son have to speak with anyone else in order to use Golden Spring New York money for your benefit?

A Yes.

Q Who does your son need to speak with?

A He needs to talk to my family member, which includes more than 100 family members, and that because they have a fund.

THE PRIVATE INTERPRETER: That -- the number is 181.

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 48 1 BY MS. CLAIBORN: 2 Mr. Kwok, if your son wanted to give you റ്റു က \$100, would he have to seek authority from someone এ at Golden Spring New York? 5 I don't know. A હ When you say your son has to speak with ் 7 someone at Golden Spring New York, how many people 8 does he need to speak with? 9 A I don't know details. With respect to the \$8 million that Golden 10 ் 11 Spring New York is willing to loan you, did your son have to obtain consent of other people at Golden 12 13 Spring New York for that transaction? 14 A I don't know. 15 Have you ever been to the office of Golden ೧ 16 Spring New York in New York City? A 17 Yes . 18 Q How often do you go to the Golden Spring 19 1 New York office in New York City? Not -- not fixed. Sometimes I go there a 20 A few times a month. Sometimes I haven't -- I haven't 21 22 gone there for a few months. 23 Q When was the last time you went to the 24 Golden Spring New York office? 25 A Yesterday.

Case 1:23-cr-001

| | Ho Wan Kwok - April 6, 2022 | |----|----------------------------------------------| | 1 | Q Why did you go? | | 2 | A For preparing today's meeting. | | 3 | Q Did your son speak with Yanping Wang about | | 4 | the \$8 million loan? | | 5 | A I don't know. | | 6 | Q Did you negotiate the terms of the \$8 | | 7 | million loan from Golden Spring New York? | | 8 | A No. | | 9 | Q Who was the person who negotiated the \$8 | | 10 | million loan on your behalf? | | 11 | A My attorney. | | 12 | Q Which attorney? | | 13 | A Aaron Mitchell. | | 14 | Q Who did Attorney Aaron Mitchell negotiate | | 15 | with at Golden Spring New York? | | 16 | THE OFFICIAL INTERPRETER: Can you repeat | | 17 | one? | | 18 | BY MS. CLAIBORN: | | 19 | Q Who did Attorney Aaron Mitchell negotiate | | 20 | with at Golden Spring New York? | | 21 | A I don't know. My son. | | 22 | Q Did you borrow the sum of \$1 million from | | 23 | Lamp Capital, LLC in February 2022? | | 24 | A Yes. | | 25 | Q Is that loan from Lamp Capital, LLC in |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 50 1 writing? 2 A No . 3 What are the loan terms of the loan from റ 4 Lamp Capital? 5 A I don't know detail. 6 Q Who are the members of Lamp Capital, LLC? 7 A My son. 8 Are there any other members of Lamp റ്റ 9 Capital, LLC? 10 A I don't know. 11 റ്റു Who is the managing member of Lamp 12 Capital, LLC? 13 I don't know. A 14 ဝ Who was the person at Lamp Capital who 15 authorized the loan? 16 A My son. What are the assets of Lamp Capital, LLC? 17 Q I don't know. 18 A 19 ್ನ What does Lamp Capital own? 20 A I don't know. 21 Have you ever funded Lamp Capital in any റ്റു 22 way? 23 A No . 24 Have you ever invested any money in Lamp ্র 25 Capital, LLC?

Ho Wan Kwok - April 6, 2022 51

1 A No. 2 Q Why did Lamp Capital loan you the \$1 3 million and not Golden Spring New York? 4 A I don't know. 5 Q What is the source of the \$1 million that 6 Lamp Capital loaned to you? 7 A I don't know. 8 MS. CLAIBORN: Why don't we take a five- 9 minute break for the restroom? We'll reconvene 10 actually, at 12:10. 11 (Recess) 12 MS. CLAIBORN: We are back on the record 13 after a short break. 14 Mr. Kwok, you remain under oath. 15 BY MS. CLAIBORN: 16 Q Mr. Kwok, were you involved in the 17 selection of the lawyers who represent you in your 18 action in London? 19 A Yes. 20 Q Did your counsel in London request a 21 retainer? 22 A Yes. 23 Q And did you pay your counsel in London a 24 retainer? 25 A Yes.

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 52 1 ್ How much? 2 A 300,000 pound. ന And when was that 300,000 pound retainer ੁ র্ব paid? 5 A Roughly two years ago. 6 ್ Who funded the retainer? 7 My son helped to pay -- pay that. A 8 Did your son pay all of the retainer? റ 9 A Yes . 10 ் Did your son pay the retainer out of his 11 personal funds? 12 A Should be from the company, England. 13 이 What was the name of the company who paid 14 the retainer? 15 A I don't remember. 16 Q Did Golden Spring New York pay the 17 retainer to your London counsel? 18 A I don't remember details because other 19 than the retainer and the other -- a few more 20 payments in -- you know, after. 21 Mr. Kwok, if you wanted to go buy a pair O 22 1 of shoes, how would you pay for a pair of shoes? 23 A -I will ask Golden Spring New York to pay 24 for it. 25 And how would that process work?

Ho Wan Kwok - April 6, 2022 53 1 A And I will talk to the director and E Wa 2 Wang (ph) and ask her to contact -- talk to my son ನ and to pay for the shoes. ਪੁ How does the shoe company get the money? o ്ഥ The shoe store. 6 I don't know. Usually, it's E Wa Wang and A r communicate, because my English ability is not છ capable to communicate. ರಿ If you went to a store, tried on shoes, இ and wanted to take them home from the store, how 10 would you pay for the shoes? The befor 11 12 A In the recent few years I basically never bought a pair of shoes. I had and 13 . 14 Q What was the last thing you paid for? A Recently, I didn't go to buy anything. 15 16 MR. BALDIGA: I'm sorry. Could you repeat 17 that? THE OFFICIAL INTERPRETER: Recently, I 18 19 didn't go to buy anything. 20 BY MS. CLAIBORN: 21 Q My question wasn't recently. My question 22 was, what was the last thing that you purchased? I don't remember. 23 A 24 Q Do you ever eat in a restaurant? 25 A Recent years, I didn't.

Ho Wan Kwok - April 6, 2022 ટે વે 1 Before COVID 19, did you eat in 2 restaurants? ന A Very rare because I was afraid to be ধ killed by the people behind me, because I was always 5 in the process getting chased. ് When you ate in a restaurant, were you the o 7 person who paid the bill? 8 A I don't have money to pay, so that's why I ் don't go there. 10 Q Mr. Kwok, if you wanted to go buy a cup of 11 coffee, how would you pay for it? 12 A I never bought a cup of coffee. I was --13 I'm afraid the people behind me might poison me in 1 4 the coffee. 15 Mr. Kwok, if you wanted to buy water, ै 16 you're out and about and you want to buy water, how 17 would you pay for it? Well, since 2107, I don't -- I didn't go 18 A 19 out to buy water outside. 20 THE PRIVATE INTERPRETER: There was a 21 (indiscernible) difference in the nuance. 22 THE OFFICIAL INTERPRETER: Can you -- can 23 you repeat it -- can you repeat --24 THE WITNESS: Since 2017, I never went 25 1 outside, walk around, and then buy water or coffee.

ument 312-2 Filed 04/30

| | Ho Wan Kwok - April 6, 2022 55 | | |-----------------------------------------------------------------|---------------------------------------------------|--------------------------------------------| | 1 | BY MS. CLAIBORN: | | | 2 | Q Mr. Kwok, do you have any interest in any | | | 3 | mutual funds? | | | 4 | A No. | | | 5 | Q Do you own any bonds? | | | 6 | A No. | | | 7 | Q Do you own any publically traded stock in | | | 8 | any company? | | | 9 | A No. | | | 10 | Q Do you own any cars? | | | 11 | A No. | | | 12 | Q Do you have access to any cars? | | | 13 | A Yes. | | | 14 | Q And whose cars do you have access to? | | | 15 | A My son's and Golden Springs. | | | 16 | Q Does Golden Spring provide you with a car | | | 17 | that's yours to use? | | | 18 | A Yes. | | | 19 | Q What kind of car is that? | | | 20 | A Maybach | | | 21 | THE PRIVATE INTERPRETER: Maybach. | | | 22 | THE OFFICIAL INTERPRETER: Huh? | | | 23 | THE PRIVATE INTERPRETER: Maybach. | | | 24 | THE OFFICIAL INTERPRETER: Maybach? Okay. | | | 25 | I don't know the name of it. I was | | | Ho Wan Kwok - April 6, 2022 56 | | | | 1 | | THE WITNESS: Maybach. | | 2 | | BY MS. CLAIBORN: | | 3 | Q | Mr. Kwok, do you have a driver's license? | | 4 | A | I have a Hong Kong's driver's license. | | 5 | Q | Do you drive in the United States? | | 6 | A | Almost no. | | 7 | Q | When you do drive, whose car do you drive? | | 8 | A | Golden Spring's. | | 9 | Q | Do you keep a car at your Greenwich | | 10 | | residence? | | 11 | A | Yes. | | 12 | Q | And what car is that? | | 13 | A | Maybach. | | 14 | Q | Do you own any aircraft? | | 15 | A | No. | | 16 | Q | Have you ever owned any aircraft? | | 17 | A | Before, yes. | | 18 | Q | When did you own aircraft? | | 19 | A | Probably 2010 to 2016. | | 20 | Q | How many air craft did you own? | | 21 | A | One. | | 22 | Q | And what was it? | | 23 | A | Airbus 319. 319. | | 24 | Q | And what happened to the Airbus 319? | | 25 | A | It was confiscated by UBS and the Chinese | | | Ho Wan Kwok - April 6, 2022 57 | | | 1 | Communist Party. | | | 2 | Q Okay. Do you own any water craft? | | | 3 | A No. | | | 4 | Q Who owns the yacht known as the Lady May? | | | 5 | A My daughter. | | | 6 | Q Does your daughter own the Lady May in her | | | 7 | personal name? | | | 8 | A Should be from a company. | | | 9 | Q And what is the name of the company that | | | 10 | owns the Lady May? | | | 11 | A I don't know. | | | 12 | Q Where is the Lady May currently? | | | 13 | A I don't know. | | | 14 | Q Since the bankruptcy filing, have you | | | 15 | asked your daughter to return the Lady May to New | | | 16 | York? | | | 17 | A I did ask her and asked her to talk to her | | | 18 | attorney to return the boat back to New York. | | | 19 | Q When did you have that conversation? | | | 20 | A Last month, after the court date. After | | | 21 | met with you. | | | 22 | Q And what did your daughter say? | | | 23 | A She said that she would talk to her | | | 24 | attorney and then talk to my attorney. | | | 25 | Q Did your daughter agree to have the Lady | |

Fiore Reporting and Transcription Service, Inc.

58 Ho Wan Kwok - April 6, 2022 1 May return to New York? 2 She was not willing to talk to me in any A detail. She want -- she wanted to talk to her က র্ব attorney. 5 Q Did your daughter say no to your request 6 that she return the Lady May to New York? No, he didn't -- she didn't. 7 A THE PRIVATE INTERPRETER: The question was 8 9 not completely interpreted. THE OFFICIAL INTERPRETER: I know, but she 10 -- she already -- he already answered and ---11 MR. BALDIGA: Wait until he finishes. 12 13 THE WITNESS: No, he -- no. 14 BY MS. CLAIBORN: Mr. Kwok, do you own or have an interest 15 ဝ 16 in any trust? 17 A No . Are you the beneficiary of any trusts? 18 ੁ 19 A No . This is a long question. Mr. Kwok, where 20 റ്റ is the \$12,000 check paid to you in connection with 21 22 your lawsuit against Baosheng Guo? It's in attorney's escrow account. 23 A What is the name of the attorney who is 24 റ 25 1 holding the check?

ge 60 of 134

| Ho Wan Kwok - April 6, 2022 59 | | | |--------------------------------|---|---------------------------------------------------| | 1 | A | I can't pronounce the attorney's name | | 2 | | completely. | | 3 | Q | What is the attorney's first name? | | 4 | A | I cannot -- I'm not able to read out the - | | 5 | | - the pronounce his name. | | 6 | Q | Is the attorney who's holding the check | | 7 | | the same attorney who represented you in that | | 8 | | lawsuit? | | 9 | A | It should be. | | 10 | Q | On your Schedule A-B, you did not disclose | | 11 | | that \$12,000 check. Why? | | 12 | | MR. BALDIGA: Wait for a question. No. | | 13 | | Could he interpret that? | | 14 | | BY MS. CLAIBORN: | | 15 | Q | Why did you not disclose that \$12,000 | | 16 | | check? | | 17 | A | My attorney thinks because the money is | | 18 | | not in my account, so I'm not allowed to -- we're | | 19 | | not -- I'm not supposed to disclose that. | | 20 | Q | Okay. Mr. Kwok, do you have any patents? | | 21 | A | No. | | 22 | Q | Do you have any copyrights? | | 23 | A | No. | | 24 | Q | Do you have any intellectual property of | | 25 | | any kind? |

Fiore Reporting and Transcription Service, Inc.

୧୦ Ho Wan Kwok - April 6, 2022 1 A No . 2 MR. BALDIGA: Excuse me. Holley, I'm not sure if you're qoing to come back to it, but there 3 র্বা is a reference to the \$12,000. 5 MS. CLAIBORN: I did see that. MR. BALDIGA: Oh, you said he didn't િ 7 disclose it. MS. CLAIBORN: He did not. It's not in 8 response to the questions on Schedule A-B. 9 10 MR. BALDIGA: It's right there. 11 MS. CLAIBORN: We can disagree about whether or not it's disclosed, but it's my position 12 that it's not disclosed. I understand you might 13 । take a different position. 15 BY MS. CLAIBORN: Mr. Kwok, do you own any interest in a 16 company called Ace Decade Holdings Limited? 17 18 A Yes. What is the nature of your ownership 19 ဝ interest in Ace Decade Holdings Limited? 20 So I have the interest and ask for UBS to 21 A pay back \$500 million. That kind of interest. 22 23 Q Are you the only legal owner of Ace Decade 24 Holdings Limited? 25 THE OFFICIAL INTERPRETER: Are you the

| Ho Wan Kwok - April 6, 2022 61 | | |--------------------------------|-----------------------------------------------------| | 1 | only -- can you repeat that question? | | 2 | BY MS. CLAIBORN: | | 3 | Q Are you the only legal owner of Ace | | 4 | Decades? | | 5 | A I am a legal representing owner. | | 6 | Q Are there any other owners of Ace Decade? | | 7 | A No. | | 8 | Q When did you become an owner of Ace Decade | | 9 | Holdings Limited? | | 10 | A At the end of 2014. | | 11 | Q This is a long question. In your | | 12 | litigation in London against UBS, you are an | | 13 | individual plaintiff. What is the basis for your | | 14 | claim as an individual plaintiff? | | 15 | A Because I'm the 100 percent representative | | 16 | for Ace Decade. | | 17 | Q In the litigation against UBS in London, | | 18 | there is an allegation that Ace Decade gave \$500 | | 19 | million to Dawn State Limited. Where did Ace Decade | | 20 | get the \$500 million? | | 21 | A I loan from my family. | | 22 | Q Did you borrow money from your family and | | 23 | give it to Ace Decade? | | 24 | A Yes. | | 25 | MS. CLAIBORN: I don't think that |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 62 ﺒﻴﺒ let's start over, because I don't think that was --2 that was --ന THE PRIVATE INTERPRETER: Yeah, I thought বা that it was --5 MS. CLAIBORN: -- that was the question, because it didn't involve Dawn State --6 7 THE PRIVATE INTERPRETER: Yes. ထ MS. CLAIBORN: -- so I'm qoing to start ி over. 10 BY MS. CLAIBORN: 11 Where did you get the money to give to Ace 12 Decade, the 500 million? MR. BALDIGA: I don't think he said he did 13 14 that. I think he said his family did that, but you can ask that, but I --15 THE WITNESS: From my family. 16 17 BY MS. CLAIBORN: Who specifically in your family gave you 18 o 19 | money that you then gave to Ace Decade? 20 A John Way (ph) . 21 ್ನ Who is John Way? 22 A A member from my family. 23 Is he a relative of yours? റ്റു 24 It's my older brother's cousin or --A 25 THE PRIVATE INTERPRETER: Son-in-law.

| Ho Wan Kwok - April 6, 2022 63 | | |-----------------------------------------------------------------|------------------------------------------------------| | 1 | THE OFFICIAL INTERPRETER: Son-in-law? | | 2 | Okay. Sorry. | | 3 | BY MS. CLAIBORN: | | 4 | Q On your Schedule A-B, you list a possible | | 5 | malpractice claim against Boise Schiller. Can you | | 6 | please explain what that is? | | 7 | A He was the one -- he was the one | | 8 | represented me in New York to have a lawsuit against | | 9 | UBS. He gave a lot of forced documents to the Court | | 10 | and without my permission. He also threatened my | | 11 | family. He also threaten myself after drinking. He | | 12 | brought a lot of loss to us, including providing any | | 13 | English/Chinese translated documents to me before | | 14 | present them to the -- to the lawyer, or to the | | 15 | judge. That's why I -- that's why we sue him. | | 16 | Q Have you hired an attorney to represent | | 17 | you in that malpractice action? | | 18 | A My son is in the process of dealing with | | 19 | that. | | 20 | Q Why is your son talking to lawyers about | | 21 | your malpractice claim? | | 22 | A Because I need to borrow money from him. | | 23 | Q Has a lawyer been selected? | | 24 | A Not yet. | | 25 | Q Mr. Kwok, do you own an interest in any | | 1 | company aside from Ace Decade? | | 2 | A No, but the -- I own the Bravo Luck, the | | 3 | apartment, only for a few months, some of the | | 4 | interest. And because the apartment is a co-op, so | | 5 | they used my name to buy the apartment after I -- | | 6 | after we bought apartment, and then we returned the | | 7 | stock interest back. | | 8 | UNIDENTIFIED SPEAKER: I'm sorry. He must | | 9 | have spoken for 30, 40 seconds. Clearly said more | | 10 | than that. Is there a more fulsome translation? | | 11 | THE OFFICIAL INTERPRETER: Did I miss | | 12 | anything? | | 13 | MS. CLAIBORN: Let me see if I can follow | | 14 | up. | | 15 | BY MS. CLAIBORN: | | 16 | Q Mr. Kwok, do you own, currently, an | | 17 | interest in Bravo Luck? | | 18 | A No. | | 19 | Q Mr. Kwok, do you own an interest in any | | 20 | limited liability company? | | 21 | A No. | | 22 | Q Mr. Kwok, do you own an interest in any | | 23 | partnership? | | 24 | A I used to own the plane company called the | | 25 | Orange or Shiny Time, but that was before and | | Ho Wan Kwok - April 6, 2022 65 | | | 1 | doesn't exist anymore. | | 2 | Q Mr. Kwok, do you currently own an interest | | 3 | in any partnership? | | 4 | A No. | | 5 | Q Mr. Kwok, do you currently own an interest | | 6 | in any joint venture? | | 7 | A No. | | 8 | Q Other than Ace Decade, do you own an | | 9 | interest in any other company right now? | | 10 | A No. I only owned the Orange and Shiny | | 11 | Time before, but not right now. | | 12 | Q Does Golden Spring New York have a | | 13 | security interest in any of your litigation? | | 14 | A I owe them money. | | 15 | Q Have you granted to Golden Spring New | | 16 | York, any interest in any of your assets, anything | | 17 | that you own? | | 18 | A No. | | 19 | Q So if you were to win a lawsuit against | | 20 | Golden Spring -- sorry. Wrong name. So if you were | | 21 | to win a lawsuit against UBS, would any of the money | | 22 | that you win have to be paid to Golden Spring? | | 23 | A Yes. | | 24 | Q And how much would that be? | | 25 | A Before it was 2,200 million, or |

Fiore Reporting and Transcription Service, Inc.

ર વ

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 66 1 THE PRIVATE INTERPRETER: 21 million. 2. THE WITNESS: 21 million. 21 million and က plus now. Probably it's about 300 million. 30 যা million. Or 30 million. Yeah. 5 BY MS. CLAIBORN: 6 o Is there a document that says that any 7 litigation winnings you receive need to be paid to 8 Golden Spring? ರು A Yes . What is the name of that document? 10 o THE OFFICIAL INTERPRETER: I'm going to 11 12 ask him to repeat it. 13 I didn't get it. I just ask him to break 14 it down, then I didn't hear what --15 THE WITNESS: I have a case in DC. There is a attorney office representing me for political 16 17 asylum and it was attacked by the cyber attack from 18 the Chinese Communists, and so they -- the attorney 19 office was closed, and they gave my personal information to the communist party, and then I sue 20 21 them. And that litigation fee, attorney fee, came 22 from Golden Spring New York. 23 I ask for the settlement for 50,000 -- \$50 million. If I won that money, I will give the money 24 25 - 1 back to Golden Springs for the money they supported

| Ho Wan Kwok - April 6, 2022 | 67 | |-----------------------------|------------------------------------------------------| | 1 | me for attorney fees. | | 2 | THE PRIVATE INTERPRETER: Mr. Kwok did not | | 3 | say settlement. Mr. Kwok just say, for a claim, not | | 4 | a settlement. | | 5 | THE OFFICIAL INTERPRETER: You're asking | | 6 | for \$50 million. Yeah. He ask for \$50 million for | | 7 | that lawsuit, and if he win -- if he wins the money, | | 8 | then he will return the money back to the Golden | | 9 | Spring New York. | | 10 | BY MS. CLAIBORN: | | 11 | Q My question was, what was the name of the | | 12 | document under which you would be repaying Golden | | 13 | Spring for your litigation? | | 14 | A The document is the document I -- | | 15 | THE OFFICIAL INTERPRETER: Can you repeat | | 16 | that one? | | 17 | THE WITNESS: The agreement is -- it's the | | 18 | agreement, I borrowed the money from Golden Spring | | 19 | New York to sue the attorney office. | | 20 | BY MS. CLAIBORN: | | 21 | Q And what is the name of the agreement? | | 22 | A I don't remember. | | 23 | Q Is it a promissory note? | | 24 | A I don't remember. |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 68 I don't remember clearly. 1 A 2 ੂ Who prepared the document? က A Attorney. What was the name of the attorney who র্ব o prepared the document? ഹ 6 A Melissa. 7 What is Melissa's last name? Q 8 A I don't know. ੇ o Did Melissa the attorney represent you in 10 drafting that document? 11 A Yes . And who represented Golden Spring in 12 Q 13 drafting that document? 14 A I don't know. 15 ্ৰ Did Golden Spring have any attorney? 16 A Yes . 17 You just don't remember who it was? O 18 ਧੋ They have a lot of attorneys. 19 റു Is there more than one written agreement under which you owe money to Golden Spring New York? 20 21 A Yes . 22 ್ತ How many agreements are there? 23 Kind of two or three, or three or four. I A 24 don't remember clearly. 25 Q And does someone keep track of the money

Document 312-

Ho Wan Kwok - April 6, 2022 69

1 that you borrow from Golden Spring New York? 2 A My attorney will write it down. We record 3 it. 4 Q What's the name of that attorney? 5 A Aaron Mitchell. 6 Q Did you say Aaron Mitchell? 7 A Oh, yes. 8 Q And how does Aaron Mitchell keep track of 9 the monies that you borrow from Golden Spring New 10 York? 11 A In detail, I don't know. 12 Q Does anyone who is employed by Golden 13 Spring New York keep track of the money that you 14 borrow from Golden Spring New York? 15 A I don't know. 16 Q Have you ever seen a document from 17 Attorney Aaron Mitchell showing how much you owe to 18 Golden Spring New York? 19 A This is the thing I -- it's something 20 between me and my attorney I shouldn't answer. 21 MR. BALDIGA: Can I -- I mean -- 22 MS. CLAIBORN: I don't think the question 23 involves -- 24 MR. BALDIGA: You can -- 25 MS. CLAIBORN: -- a privileged answer.

Fiore Reporting and Transcription Service, Inc.

| | Ho Wan Kwok - April 6, 2022 70 | |----|------------------------------------------------------| | 1 | MR. BALDIGA: That's -- give me a second. | | 2 | You could answer that last question yes or no, so if | | 3 | you ask again, I think he will say yes or no, and | | 4 | then we can take it step by step. | | 5 | BY MS. CLAIBORN: | | 6 | Q Have you ever seen a document prepared by | | 7 | Attorney Mitchell that shows you how much money you | | 8 | have borrowed from Golden Spring? | | 9 | MR. BALDIGA: Wait. Wait, my instruction | | 10 | needs to be interpreted. | | 11 | THE OFFICIAL INTERPRETER: What? | | 12 | MS. CLAIBORN: Can you -- | | 13 | MR. BALDIGA: You need to instruct -- | | 14 | MS. CLAIBORN: Just please state it and | | 15 | he'll reinterpret. | | 16 | MR. BALDIGA: Please, tell the witness | | 17 | what -- I am telling the witness he may answer yes | | 18 | or no only. | | 19 | THE WITNESS: Yes. | | 20 | MS. CLAIBORN: I have other questions, but | | 21 | given the hour of the day, I thought that we could | | 22 | take a short break and then reconvene with creditors | | 23 | being given the opportunity to ask questions. | | 24 | I suggest we reconvene at 1:15. | | 25 | MR. BALDIGA: Is that okay? |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 71

MS. CLAIBORN: Okay. Thank you. We'll reconvene at 1:15.

(Recess.)

MS. CLAIBORN: The recording has been reconvened. We are back in session after a short break and Mr. Kwok, you remain under oath. And that this point, Mr. Wolman has some questions for you, Mr. Kwok.

EXAMINATION BY MR. WOLMAN:

Q Good afternoon, Mr. Kwok. On March 21st I was asking you some questions about a prior deposition, specifically about the times you had invoked your rights under the Fifth Amendment of the U.S. Constitution. On April 1st, 2021, were you being investigated for any crime?

THE OFFICIAL INTERPRETER: April 21st?

MR. WOLMAN: April 1st, 2021.

THE OFFICIAL INTERPRETER: Can you repeat that question, sir?

Q Were you being investigated for any crime?

A From SET -- American SET and the investigating GTV and they can communicate with our attorney.

Q Are you referring to the Securities and

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 72 r + Exchange Commission? 2 A Yes . က Q And what exactly were they investigating? বা MR. BALDIGA: Objection. ഹ I need to ask whether this would reveal 6 privileged information. 7 Would your answer to the last question be 8 information from your attorneys? 9 THE PRIVATE INTERPRETER: Can I just --10 THE OFFICIAL INTERPRETER: She wants to 77 help. 12 THE PRIVATE INTERPRETER: Because he's not 13 14 MS. CLAIBORN: I think you should just try 15 again. Mr. Baldiga, maybe you can just repeat 16 yourself and Mr. Jack, you can try again. 17 THE OFFICIAL INTERPRETER: Can you repeat 18 what you want to say? 19 MR. BALDIGA: Mr. Wolman asked you what 20 you were being investigated for. Is the information 21 that you know, was that provided to you by your 22 attorneys? 23 THE WITNESS: Yes. 24 MR. BALDIGA: And to answer the question 25

Ho Wan Kwok - April 6, 2022 73

attorneys? THE OFFICIAL INTERPRETER: Have to be what? Divulged? MR. BALDIGA: Would you have to say what you were told by your attorneys? THE WITNESS: Yes. MR. BALDIGA: Then I instruct the witness not to answer on the basis of the attorney/client privilege. MR. WOLMAN: That is not attorney/client information. MR. BALDIGA: Hold on. Let it be interpreted. MR. WOLMAN: Information learned from an attorney that is not specifically a communication for the purpose of giving advice or receiving information is not privileged information. If your attorneys says the sky is blue, that is not a privileged communication. MR. BALDIGA: His is arguing with me. There is not question to you. MR. WOLMAN: Mr. Baldiga, will you continue to instruct your client to improperly invoke the attorney/client privilege? MR. BALDIGA: I'll instruct on a question

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 74 1 by question basis. 2 MR. WOLMAN: And this question, will you က maintain the instruction? বী Mr. Kwok, are you refusing to answer my 5 question? 6 THE WITNESS: Yes. 7 MR. WOLMAN: And on what basis are you ထ refusing to answer my question? ರು MR. BALDIGA: On the basis of instruction 10 from counsel on account of attorney/client 11 privilege. 12 THE WITNESS: Because I can't answer the 13 question because of the privilege between the 14 attorney and me. 15 BY MR. WOLMAN: 16 Q Have you been formally charged by the 17 Securities and Exchange Commission? 18 A No . 19 Q Has the Securities and Exchange Commission 20 closed its investigation of you? 21 MR. BALDIGA: I have to ask again, you can 22 - 1 answer that yes or no, if you know. 23 A No . 24 Q Has the Securities and Exchange Commission 25 ' brought any charges against GTV?

Filed 04/30/24

Ho Wan Kwok - April 6, 2022 75

1 A I don't know. 2 Q Have you been in the past five years 3 subject to an audit by the U.S. Internal Revenue 4 Service? 5 A No. 6 Q In the last five years have you been 7 subject to an audit by the New York State taxing 8 authority? 9 A No. 10 Q When did you become a resident of 11 Connecticut? On what date? 12 A The beginning of March, 2020, roughly. 13 Q To be clear, you say you were a resident 14 of Connecticut in March of 2020? 15 A Yes. 16 Q So how come in Mr. Cheng, my client's, 17 lawsuit against you you signed a statement under 18 oath indicating that you were a resident of the 19 Sherry Netherlands Hotel? 20 THE OFFICIAL INTERPRETER: Can you repeat 21 that, counsel? 22 Q If you were a resident of Connecticut in 23 March of 2020, you signed a statement under oath in 24 Mr. Cheng's lawsuit against you that you resided at 25 the Sherry Netherlands Hotel.

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 76 1 A I don't 100 percent live in Connecticut, 2 but sometimes I live in New York also. ന Q When did you start living in Connecticut বা more than 50 percent of the time? 5 A Since March, 2020. ર റ്റ You had some assets you claim seized by 7 China, correct? 8 A It's not mine. It's from my family. It's த my family's. 10 ্ত Have you ever had assets seized by China? 11 A You're talking about under my name? 12 O Yes. 13 A No . 14 ್ತ All right. In 2010, what was your 15 personal net worth? 16 A No . 17 Q That wasn't a yes or no question. 18 THE OFFICIAL INTERPRETER: Can I repeat 19 your question again? 20 MR. WOLMAN: Yes. 21 ு In 2010 what was your personal net worth? 22 A I didn't have any property. 23 Have you ever had property in your name Q 24 over \$1 million and by that I include where you 25 ' owned an interest in a company that interest,

312-2 Filed 04/30

| | Ho Wan Kwok - April 6, 2022 | 77 | |--------------------------------|----------------------------------------------------|-----------------------------------------------------| | 1 | | therefore, contributes to your work? | | 2 | A | Before 2000, yes. | | 3 | Q | Okay. What was your net worth in 1999? | | 4 | A | I never calculate in detail. | | 5 | Q | What would you estimate it as? | | 6 | A | Roughly around 100 million. | | 7 | Q | And what happened to that \$100 million | | 8 | | worth of assets? | | 9 | A | Because in 2000 I got a Hong Kong passport | | 10 | | and in China and they don't allow me to have any | | 11 | | property, asset. | | 12 | Q | Have you abandoned all claims to whatever | | 13 | | assets you had in 1999? | | 14 | A | Yes. | | 15 | Q | Why have you abandoned your claims? | | 16 | | THE OFFICIAL INTERPRETER: Abandoned what? | | 17 | Q | Your claim to those assets? | | 18 | A | Because I was not allowed to have any | | 19 | | assets in China. | | 20 | Q | If China changed its policy, would you | | 21 | | have any right or ability to get those assets back? | | 22 | | MR. BALDIGA: Objection. If you know, you | | 23 | | can answer. | | 24 | A | I don't know. | | 25 | Q | What was your largest asset in 1999? | | Ho Wan Kwok - April 6, 2022 78 | | | | 1 | A There was the assets from a hotel, equity | | | 2 | interest of a hotel in China. | | | 3 | Q And who holds that interest now? | | | 4 | A Chinese Community Party. | | | 5 | Q Is it held in the name of the Party? | | | 6 | A China only has one autocrat government, | | | 7 | the party, and our family's assets were taken -- | | | 8 | were seized by them. | | | 9 | Q How did your son become wealthy enough to | | | 10 | fund Golden Spring and Lamp Capital? | | | 11 | A Because he started very early to do | | | 12 | investment and also bring brand names to China. | | | 13 | Q Where did he get the money for his | | | 14 | investment? | | | 15 | A I don't know. | | | 16 | Q Ms. Claiborn asked you about agreements | | | 17 | with Golden Spring and you could not identify who | | | 18 | the lawyer was for Golden Spring. Do you remember | | | 19 | that? | | | 20 | A True. | | | 21 | Q I'd like to try to refresh -- to ask you | | | 22 | potentially to refresh your memory was it a lawyer | | | 23 | named Daniel? | | | 24 | THE OFFICIAL INTERPRETER: He's asking | | | 25 | Daniel? | |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 79 1 Q Yes, Daniel Pedolsky. 2 A Yes, probably and he used to be Golden 3 Spring attorney and my personal attorney. 4 Q Did you execute a waiver of conflict of 5 interest with Mr. Pedolsky? 6 THE OFFICIAL INTERPRETER: Can you repeat 7 that? 8 Q Did you execute a waiver of conflict of 9 interest with Attorney Daniel Pedolsky? 10 A I don't remember. 11 Q You mentioned two or three -- or three or 12 four agreements with Golden Spring. Can you identify 13 each of those agreements? 14 A I'm not sure. 15 Q Can you describe the purpose of each of 16 those agreements? 17 A That loan from Golden Spring is to have a 18 settlement with Logan Cheng. 19 Q And did you take out a loan to pay the 20 lawyers to sue Logan Cheng? 21 A I don't remember. 22 Q And what were the other agreements, other 23 than with Mr. Cheng? 24 A From D.C. -- the attorney's office from 25 D.C. collect (indiscernible) I don't remember the

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 80 1 name . 2 MR. WOLMAN: All right. Thank you and က this time I have to go but thank you. I'll try to ്ച് dial in. MS. CLAIBORN: Thank you. 5 6 Can I ask whoever is on the line if they 7 could mute themselves, because they can hear you 8 typing. All right. Who else would like to ask ் 10 questions? Mr. Harbach. Go ahead, Mr. Harbach. 11 MR. HARBACH: Thank you. For the record, 12 13 I'm David Harbach with O'Melveny and Meyers and I 14 represent PAACS. 15 EXAMINATION BY MR. HARBACH: Q Mr. Kwok, I'd like to ask some clarifying 16 17 questions based on questions that Ms. Claiborn asked 18 you today. 19 Earlier today she asked you if you owned 20 any foreign currency and you said no. She also asked you if you owned any digital currency and you 21 22 said no. 23 My question is have you ever ordered or directed the purchase of either foreign currency or 24 25 ' diqital currency on behalf of any entity?

Case 1:23-cr-00118-AT D

| | Ho Wan Kwok - April 6, 2022 81 | |----|------------------------------------------------------| | 1 | THE OFFICIAL INTERPRETER: Can you repeat | | 2 | that? | | 3 | MR. HARBACH: Sure. | | 4 | Q My question is whether you have ordered or | | 5 | directed the purchase of any foreign currency or any | | 6 | digital currency on behalf of any entity? | | 7 | A What you mean direct? | | 8 | Q Have you directed anyone to purchase | | 9 | foreign currency or digital currency? | | 10 | A No. | | 11 | Q Ms. Claiborn asked you a couple of | | 12 | questions about access to credit cards and debit | | 13 | cards. And I want to make sure that we have your | | 14 | answer clear, because she asked you not whether you | | 15 | had any credit cards but whether you had any access | | 16 | to credit cards. I want to make sure that you | | 17 | understand the difference. | | 18 | THE OFFICIAL INTERPRETER: He's just asking | | 19 | why you want to represent Ms. Holley's asked | | 20 | questions. | | 21 | MR. HARBACH: I'm just trying to remind | | 22 | you of a question she asked you earlier today, sir. | | 23 | THE PRIVATE INTERPRETER: I don't | | 24 | understand the question. | | 25 | MR. BALDIGA: Mr. Baldiga's right. |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 82 1 There's not a question pending. 2 The question is do you understand the റ്റു ന difference between having a credit card and having বা access to a credit card? 5 A I believe I don't have. ર્ભ O You don't understand the difference? 7 -A I don't know much. ထ Okay. Well, let me give you an example. റു Let's talk about the Maybach. 10 I believe that you represented to us today 11 that you have access to the Maybach for 12 transportation. Is that correct? 13 । ਸ Yes . ਹੈ ਕੇ ্ But I believe it's also your position that 15 you do not own the Maybach. Isn't that right? 16 A Yes . 17 In other words, your position is the ੁ 18 Maybach is not yours, right? 19 A Yes. 20 റ Okay. So I use that example to illustrate 21 the example between owning something and having 22 access to something. Does that help you? Do you 23 understand the difference? 24 A Now I understand you. 25 ဝ Okay. Thank you. So returning to the

ട്

ર

ਉ

Ho Wan Kwok - April 6, 2022

question about credit cards and debit cards. Do you have access to any credit cards or debit cards, whether or not they are yours?

A I don't understand the difference what he means, access like if I use it myself or if I have somebody else use it.

Q Well, let's take those one at a time. Let's begin with using it yourself. Has any member of your family ever provided you a credit card or a credit card number to use for yourself?

> A : I never used.

12 Q The other example you mentioned was 13 perhaps a member of your family using a credit card on your behalf. Is that something that has 14 15 happened?

16 A - What do you mean represent me to use? 17 I'm asking about whether to your knowledge 18 any member of your family has ever used a credit 19 card or a debit card to purchase things for you?

20 A My son, my daughter, my wife. They all 21 have credit card to buy things for me.

THE PRIVATE INTERPRETER: The witness did 22 23 | not say that, use the credit card to buy things for 24 me. The witness said that my son, my wife bought 25 things for me.

Ho Wan Kwok - April 6, 2022 8 4 1 THE OFFICIAL INTERPRETER: Yeah, they used 2 their card and they both -- they all have it. They က all have the cards. That's what he said. ರ್ (Repeats interpretation) ഗ THE OFFICIAL INTERPRETER: Yes, I did it ে right. 7 THE WITNESS: And so my wife and my son ထ and my daughter have their own cards and also other 9 | family members use their cards to buy things for me. 10 Q Is that ever at your direction? No . 11 A 12 Q Never. 13 ಗೆ No . 14 റ്റു Is it at your request? 15 A No . 16 Is Yan Ping Wang, the same as Yvette Wang? ு 17 ಗೆ Yes. Earlier Ms. Claiborn asked you about 18 ு 19 - 1 Golden Spring Hong Kong. 20 You told her that your son owns it. Do 21 you recall that? 22 A Yes . 23 My question for you is since when has your റ്റു 24 son owned Golden Spring Hong Kong? 25 A I don't know.

| Ho Wan Kwok - April 6, 2022 85 | | |-----------------------------------------------------------------|------------------------------------------------------| | 1 | Q Has anyone else besides your son ever | | 2 | owned an interest in Golden Spring Hong Kong? | | 3 | A I don't remember. | | 4 | Q You also said that you didn't remember | | 5 | whether you were ever a corporate officer of Golden | | 6 | Spring Hong Kong? | | 7 | THE OFFICIAL INTERPRETER: Can you repeat | | 8 | that one? | | 9 | Q You also said that you did not remember | | 10 | whether you were ever a corpora officer of Golden | | 11 | Spring Hong Kong? Does that mean that it is | | 12 | possible that you were and you're just not certain? | | 13 | A I don't remember. | | 14 | Q Ms. Claiborn asked you in a few different | | 15 | ways about whether you know how Golden Spring New | | 16 | York is funded or makes money. | | 17 | Since when has Golden Spring been paying | | 18 | your personal living expenses? | | 19 | A 2015. | | 20 | Q So six or seven years approximately? | | 21 | A Since 2015 and that there was a person | | 22 | called Bruno Wu from Mainland China and called my | | 23 | family, my son, daughter and wife and so since then | | 24 | I start spending money coming from Golden Spring New |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 8 6 rt THE PRIVATE INTERPRETER: I don't think 2 the witness says some. 3 THE OFFICIAL INTERPRETER: What? বা THE PRIVATE INTERPRETER: I don't think ഗ the witness said some. 6 THE WITNESS: Not including the son that 7 they caught, my wife and daughter and a lot of my ထ family members, but not my son. ੇ So approximately six or seven years that o 10 Golden Spring has been paying your personal 11 expenses. Is that right? 12 A Yes . 13 Q During those six or seven years did you 14 never discuss with any of your family members where 15 the money was coming from? 16 A Because a lot of my family members were caught by -- were arrested by your client, Bruno Wu, 17 18 and so I have no communication. I cannot communicate 19 with him. 20 THE PRIVATE INTERPRETER: Not exactly. The 21 partner of PAACS -- the partner who the counsel was 22 represented, PAACS -- partner of PAACS --23 THE OFFICIAL INTERPRETER: I don't know. 24 He didn't mention anything about PAACS. 25 THE WITNESS: So it's the other attorney

Ho Wan Kwok - April 6, 2022

| 1 | representing the client, Bruno Wu, arrested a lot of | |----|------------------------------------------------------| | 2 | your family members. Your client's past partner, | | 3 | one of the partners, (indiscernible) Bruno Wu and | | 4 | arrested a lot of your family members so you can't | | 5 | communicate with them. | | 6 | Q At any time since 2015 have you been in | | 7 | communication with your daughter, or your wife, or | | 8 | your son? | | 9 | A Yes. | | 10 | Q At any time that you've been in | | 11 | communication with any of those three individuals | | 12 | did you ever ask them about where Golden Spring's | | 13 | money was coming from? | | 14 | A Yes, I asked. | | 15 | Q And who did you ask? | | 16 | A I asked all three of them. | | 17 | Q And what did they say? | | 18 | A They told me because I was in the position | | 19 | of being chased so don't ask our own financial | | 20 | information. Don't ask me for anything and we will | | 21 | help you to -- we will help you as much as we can. | | 22 | Q When was that? | | 23 | A After 2017. | | 24 | Q How long after 2017? | | 25 | A I don't remember. | | | Ho Wan Kwok - April 6, 2022 88 | | 1 | Q And when you had this conversation with | | 2 | your family were the three of them together or where | | 3 | these separate conversations? | | 4 | A Separate. | | 5 | Q And each of the three of them said more or | | 6 | less the same thing? | | 7 | A Similar. | | 8 | Q So I want to make sure I have this | | 9 | correct. You asked each of them where Golden | | 10 | Springs money was coming from and each of them said | | 11 | to you don't ask me about that because -- finish the | | 12 | sentence for me. | | 13 | A So you are making a story I don't | | 14 | understand. | | 15 | Q I'm trying to ask you to help me | | 16 | understand. I'm trying to understand the reason why | | 17 | your family members told you not to ask why your | | 18 | family members told you not to ask about where | | 19 | Golden Spring got the money. | | 20 | MR. BALDIGA: Let him ask you a question. | | 21 | Q Please tell me why each of your family | | 22 | members told you not to ask them about where Golden | | 23 | Spring money came from? | | 24 | MR. BALDIGA: Objection. If you know. | | 25 | THE OFFICIAL INTERPRETER: You're asking |

Fiore Reporting and Transcription Service, Inc.

8 d

Ho Wan Kwok - April 6, 2022

to object the question?

MR. BALDIGA: I objected.

THE OFFICIAL INTERPRETER: Oh, you

objected.

ನ

రు

MR. BALDIGA: I permit him to answer if he knows .

> THE OFFICIAL INTERPRETER: Okay. THE WITNESS: My daughter and wife were

8 arrested by his partner and got released 2017 and ರಿ released to New York. They were tortured 10 tremendously by communist party. The person 11 tortured them is this attorney's partner. They all 12 have their own attorneys. They told me don't ask me 13 or communicate with me about their own financial and 14 personal information. Anything you want to do it's 15 better go through attorneys. 1.6

This is the doctrine, the thing, my family 17 members told them before they came to New York. I 18 just want to tell you it's the meaning, very similar 19 meanings, but I can't tell you word by word. 20

So I don't want this counsel make any 21 stories about my daughter -- about my daughter's 22 forgery, giving false testimony. That kind of 23 -24 story. The last time when we were here with Ms. 25

1 Holley and he was making false lies and saying I'm 2 using my Twitter account and saying that the judge ო in New York was communist party and I didn't even বা have a Twitter account.

5 MR. HARBACH: Just so the record's clear 6 today is the first that I've uttered a word in 7 connection with this litigation in court. So I ထ don't think you're talking about me, sir.

் THE WITNESS: I was saying last time was 10 from attorney in your office. The prior attorney 11 before you called Andy Morse (ph) and was kicked out 12 by the judge because he was making false claims for five years and was kicked out by the judge. So the 13 14 law office was always making false claims.

15 MR. BALDIGA: Just answer his question 16 because I can't know whether to object unless you're 17 just trying to answer his question.

18 THE WITNESS: I didn't talk to my family, 19 daughter and wife individually to say the same 20 thing. If I say the same thing, same words, that 21 will be making false story. 22 MR. HARBACH: I understand. 23 THE WITNESS: You cannot use your 24 imagination and put it into my head. This is why

the New York South District and the judge was

Fiore Reporting and Transcription Service, Inc.

25 - 1

বাঁ

ર

ੇ

ent 312-2 Filed 04/30/2

ੇ ਹ

Ho Wan Kwok - April 6, 2022

(indiscernible) by them and they give me the wrong sentencing.

UNIDENTIFIED: Can you say that last --THE WITNESS: Because of their false claims, so that's why the judge from the south district of New York, the judge, gave me the wrong sentencing.

THE PRIVATE INTERPRETER: And also the interpreter did not interpret fully counsel's instruction to the witness previously about his objection.

MS. CLAIBORN: If you want to repeat it, 12 . ਹੈ ਤੋ go ahead.

MR. BALDIGA: I think you just have to 14 15 listen to these questions and answer just these 16 questions.

MR. HARBACH: Sorry. Counsel will move to 17 a different topic. 18

19 BY MR. HARBACH:

20 Q Mr. Kwok, Ms. Claiborn asked you today about a \$21 million debt that you owe to Golden 21 Spring. She asked you how much of that 21 million 22 23 | was legal fees and your answer was I think most of 24 it. 25 I'd like to know what you meant by most of it.

Ho Wan Kwok - April 6, 2022 92 1 Did you mean \$11 million or do you mean close to \$21 2 million. ന A I don't remember. ব Q Do you still believe that most of it was ഹ for legal fees? ్ A I don't remember. 7 -্ You also mentioned the Logan Cheng ထ settlement and that there was money borrowed from Golden Spring in connection with that. 10 A Yes. 11 റ How much money was that loan for? 12 র্মা I don't remember exactly. Probably like 200. Two -- \$300,000. 13 | 14 ্ What were the terms of that loan from 15 Golden Spring? 16 A I don't remember. 17 When Ms. Claiborn asked you if you had 18 ever been to Golden Spring's offices in New York, 19 you said yes. 20 What's the address of those offices? 21 A Yes. What is the address of those offices? 22 ் 23 A 64th Street, 162. 24 ্র You also mentioned that the last time you 25 1 were there was yesterday and that the reason you

ਰੇ ਤੇ Ho Wan Kwok - April 6, 2022 went there was to prepare for today's meeting. 1 Who did you meet with there? 2 A 3 My attorney. Did you meet with anyone else besides your 4 ್ನ attorney to prepare for today's meeting while you ನ were at the office? 6 I don't know what you mean, the other 7 A 8 people. Well, did you meet with anyone who works ਉ O 10 for Golden Spring? Yes, I met Yvonne Wang. 11 A റ And this was yesterday? 12 Yes, I met her yesterday. A 13 Did you ask some questions of her । ਪੈ o 15 yesterday? 16 A No . And tell me about your conversation with 17 း Ms. Wang? 18 What do you mean? 19 A Q Well, I'd like to know what you talked 20 about with her. 21 I ask her to arrange the food to eat and 22 A 23 the coffee. Is that all? 24 0 And also we talked about how to abolish 25 A

Ho Wan Kwok - April 6, 2022 ੇ ਪੈ 1. communist party. 2 O I want to make sure I get this right. I ന think you said --ণ MR. BALDIGA: Excuse me. Can I hear the 5 last thing again. e THE WITNESS: We talk about how to abolish 7 communist party. 8 MR. BALDIGA: Thank you. ੀ Ms. Wang is an officer of Golden Spring, 10 correct? 11 A Yes . 12 Q And you directed her to bring coffee, 13 right? 14 No, I didn't direct her. I'm just hoping A 15 her to bring some coffee. 16 റ്റ You were hoping or helping? 17 A Help. 18 ্ You were helping. Because my question to 19 you was what you talked about with Ms. Wang. And I thought you said you asked her to bring some coffee 20 21 or maybe even told her to bring some coffee. 22 A No, your attorney office -- you attorney 23 office making and imagining things aqain. I'll ask the question again. 24 ੁ 25 MR. BALDIGA: Please ask a question. Don't

Ho Wan Kwok - April 6, 2022

. 95

| | Ho Wan Kwok - April 6, 2022 | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | ﻴﻢ | put words in his mouth. | | থ | Q What did you discuss with Ms. Wanq | | ന | yesterday? | | বা ഗ | Do you want me to talk about in detail? I A can talk about this for hours. | | రు | Well, no, not if the detail concerns how o | | ി | to overthrow the Chinese Communist Party. So I'll be | | છે | more precise. | | 9 | So you don't want us to abolish Chinese A | | 10 | Community Party. Our job is to abolish Chinese | | ने के बाद में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में | Communist Party. | | 12 | MR. BALDIGA: Just answer the question. | | 13 | THE WITNESS: You don't have a question. | | ] | You're just directing something. | | 15 | Sometimes I speak in segments to allow the လ | | 16 | interpreter to translate. | | 17 | MR. BALDIGA: I think it would be helpful | | 18 | if you just ask question and then the witness | | । ਤੇ | I'll instruct him to answer your questions. That | | 20 | would be helpful. | | 21 | Did you discuss with Yvette [sic] ਂ | | 22 | yesterday anything related to preparing for the | | 23 | meeting today? | | 24 | ದ Yes . | | 5 | What did vou discuss? C |

Fiore Reporting and Transcription Service, Inc.

| 1 | A | I ask her to bring those documents here. | |----|---|-------------------------------------------| | 2 | Q | Anything else? | | 3 | A | I don't remember. | | 4 | Q | When was Lamp Capital created? | | 5 | A | I don't know. | | 6 | Q | Why was Lamp Capital created? | | 7 | A | I don't know. | | 8 | Q | Who created Lamp Capital? | | 9 | A | My son. | | 10 | Q | How do you know that? | | 11 | A | Because I borrow money from my son to pay | | 12 | | attorney fee. | | 13 | Q | The question is how do you know that your | | 14 | | son created Lamp Capital? | | 15 | A | Because my son said it. | | 16 | Q | He told you himself. | | 17 | A | Yes. | | 18 | Q | Did he ask for any advice from you about | | 19 | | whether to create Lamp Capital? | | 20 | A | No. | | 21 | Q | Did he ask you your opinion on whether he | | 22 | | should create Lamp Capital? | | 23 | A | No. | | 24 | Q | Did he tell you why he was creating Lamp | | 25 | | Capital? |

Ho Wan Kwok - April 6, 2022 97

1 A No. 2 Q When you were talking about your 3 malpractice claim against Boise Schiller, you 4 mentioned someone you kept referring to as he. I'd 5 like to know who that person is? 6 A I don't know what you mean. 7 Q Yes, that was a bad question. I apologize. 8 You stated that there was someone who gave 9 false documents to the court without your 10 permission. That this person threatened your 11 family, that this person threatened you after 12 drinking and that this person brought lots of loss 13 to you and your family, including not providing 14 translated documents before presenting them to the 15 judge. 16 My question is who is that person? 17 A Schiller. The Attorney Schiller. 18 Q So Mr. Schiller of the Boise Schiller law 19 firm. Have I got that right? 20 A Yes. 21 Q Thank you. Do you have an understanding of 22 what business Lamp Capital is engaged in, if any? 23 A No. 24 Q Different subject. You said several times 25 today in connection with your answers that the

Fiore Reporting and Transcription Service, Inc.

વે 8

| | Ho Wan Kwok - April 6, 2022 તે 8 | |------|-------------------------------------------------------| | 1 | people behind me have done certain things. | | 2 | Who are you talking about? | | 3 | One person behind me, there is a boss র্বা | | 4 | called Bruno Wu. He paid the case that -- the rape | | 5 | case from (indiscernible) rape case. Also there is | | లు | a creditor here and that also was paid by Bruno Wu. | | 7 | That attorney fee was paid by Bruno Wu. And Bruno | | 8 | Wu is also his partner and he invested \$800 million. | | 9 | Bruno Wu's partner is also (indiscernible) previous | | 1 0 | officer and they were investigating and they | | 11 | combined a partner with them to investigate my case. | | 12 | So April 18, 2017, so this (indiscernible) | | 13 | start suing me, bring the lawsuit. Within this 24 | | 1 4 | hours Bruno Wu is sending me the red note and they | | 15 | start bringing the lawsuit. | | 16 | MR. HARBACH: Can I stop -- | | 17 | THE WITNESS: The Chinese Communist Party | | ી 8 | stopped the interview, the VOA interview with me. | | । ਤੇ | They happened at the same time. | | 20 | MR. HARBACH: Or I can let him go. | | 21 | THE WITNESS: All the documents made by | | 22 | this attorney firm were all false. They provide a | | 23 | false document to the South District of New York | | 24 | court. They even false claim on my daughter's | | 25 | yacht. The boat is mine. They sought the judge |

Ho Wan Kwok - April 6, 2022 ਕੇ ਰੇ 1 from the South District Court and I file the bankrupt -- personal bankruptcy case twice and the 2 3 day -- they (indiscernible) twice including Ms. 4 Holley. And Ms. Holley was present.

The first time when Ms. Holley was present in the court and they false testified saying -- and they said my daughter was giving false testimony for the Sherry bankruptcy case because my daughter never participated in that case.

10 And Ms. Holley was there, was present the 11 second co date and Ms. Holley was there also. The 12 attorney from the firm was telling the judge and 13 they said that I used the Twitter account to -- and they said on the Twitter and I was saying on the 14 15 Twitter the south district judge was communist party member. 16

17 You can see here all the people behind me 18 and one is Bruno Wu and one person paid in many 1 9 cases --

20 MR. HARBACH: I'd like to ask another 21 question. 22 BY MR. HARBACH:

23 Q Are you aware one way or the other whether 24 your bankruptcy counsel, the Brown Rudnick law firm, 25 has ever previously represented Bruno Wu?

Fiore Reporting and Transcription Service, Inc.

ನ

ੇ

Ho Wan Kwok - April 6, 2022 100 1 THE OFFICIAL INTERPRETER: Can I take a 2 little break? I just can't concentrate as much. က Just too much. Can I take a break? খা MS. CLAIBORN: Can I ask you to ask that 5 question and then we'll take a break? ে THE OFFICIAL INTERPRETER: Yes. Can you 7 repeat that question? ထ MR. HARBACH: I'd be happy to. ை Q Are you aware one way or the other of 10 whether your bankruptcy counsel, the Brown Rudnick 11 law firm, previously represented Bruno Wu? 12 THE OFFICIAL INTERPRETER: Represent 13 somebody else you said? 14 MR. HARBACH: Yes. Bruno Wu. 15 A No . 16 MS. CLAIBORN: I'm going to take a short 17 break. We're qoing to be back here at 2:45. 18 (Break) 19 MS. CLAIBORN: All right. We are back on the record after a short break. 20 21 Mr. Harbach, the floor is yours. 22 MR. HARBACH: Thank you. 23 BY MR. HARBACH: 24 Q Ms. Kwok, among the documents in front of 25 1 you, document 78 filed in this case.

Ho Wan Kwok - April 6, 2022

101

| 1 | THE OFFICIAL INTERPRETER: Which document? | |----|------------------------------------------------------| | 2 | This one? | | 3 | MR. HARBACH: Yes. My apologies. Counsel | | 4 | advises me that your copies are not stamped. | | 5 | Q I'm talking about your official from 106. | | 6 | So my question for you starts on page 9, which | | 7 | contains a heading that says Schedule D, creditors | | 8 | who have claimed (indiscernible) by the property. | | 9 | Are you with me? | | 10 | You checked the box yes. And were | | 11 | directed to Schedule D, so that's where I would like | | 12 | you to flip to, please. And it's at page 18. | | 13 | MR. BALDIGA: What's the title? He can | | 14 | maybe find it better with the title. | | 15 | MR. HARBACH: Okay. It's the little chart | | 16 | that is Schedule D, which is a list of creditors | | 17 | with secured claims. | | 18 | BY MR. HARBACH: | | 19 | Q Mr. Kwok, you'll see that there are five | | 20 | separate entries for Golden Spring New York Limited. | | 21 | The data in each column is identical for all five | | 22 | rows. | | 23 | So my question is why are there five | | 24 | identical entries on this schedule? | | 25 | |

Ho Wan Kwok - April 6, 2022 102 1 identical entries on this schedule? 2 A I don't know what that means five -- က 0 Well, each row is exactly the same. And I'm just asking why there are five rows with the বা 5 same information? ୍ଦ A T don't know. 7 Among that documents that you filed were റു 8 | some specific notes and one of those notes discusses റ്റ the residence on Taconic Road. 10 MR. HARBACH: And for counsel I'm at 11 document 77, page 4. 12 THE OFFICIAL INTERPRETER: Which page? 13 MR. HARBACH: Page 4. 14 THE OFFICIAL INTERPRETER: 84 ? 15 MR. HARBACH: No, Page 4. THE OFFICIAL INTERPRETER: Oh, page 4. 16 Okay . 17 18 BY MR. HARBACH: 19 My question really isn't so much about the 이 exact test as it is the substance. 20 21 So first question, is it true that all expenses 22 | related to the Taconic Road House are paid directly by family and family controlled enterprises? 23 24 A Yes . 25 ্ত Okay. Which family members?

ent 312-2 Filed 04/30/24

| Ho Wan Kwok - April 6, 2022 | | 103 | | |-----------------------------|---------------------|-----------------------------------------------------|------| | 1 | A | My wife, sometimes by my son. | | | 2 | Q | Which family controlled enterprises? | | | 3 | A | Which country -- my wife. | | | 4 | Q | Your wife's not an enterprise. I'm trying | | | 5 | | to ask which family controlled enterprises pay the | | | 6 | | expenses for the Taconic House? | | | 7 | A | Greenwich LLC. | | | 8 | Q | Okay. Incidentally, how do you know that | | | 9 | | your wife and sometimes you son pay these expenses? | | | 10 | A | Because I live there. | | | 11 | Q | Do you observe them pay the expenses? | | | 12 | A | Yes. | | | 13 | Q | Is that ever at your request? | | | 14 | A | I don't remember I request anything. | | | 15 | Q | Does Greenwich Land LLC -- yes Greenwich | | | 16 | | Land LLC own any other real estate besides 373 | | | 17 | | Taconic Road? | | | 18 | A | I don't know. | | | 19 | Q | Do you know anything about the property | | | 20 | | located at 33 Ferncliff in Cos Cob, Connecticut? | | | 21 | | THE OFFICIAL INTERPRETER: Can you repeat | | | 22 | | that? | | | 23 | | MR. HARBACH: Yes. | | | 24 | Q | 33 Ferncliff in Cos Cob, Connecticut. | | | 25 | | THE OFFICIAL INTERPRETER: | | | | | Ho Wan Kwok - April 6, 2022 | 1 04 | | 1 | | No, 33. MR. HARBACH: | | | 2 | A | Yes, now I remember it. It's also owned by | | | 3 | my wife's company. | | | | 4 | ் | That being Greenwich Land? | | | 5 | ਕੇ | Maybe . | | | రా | റ്റ് | Do you know? | | | 7 | র্মা | I'm not sure. | | | రు | o | Have you ever been to 33 Ferncliff? | | | 9 | A | Yes . | | | 1 0 | ் | How recently? | | | 11 | d | Not recently. No . | | | 12 | o | Do you know when Greenwich Land purchased | | | 13 | Ferncliff? 3 ਤੋਂ | | | | । ਕੁ | A | I don't remember. | | | 15 | o | Do you know approximately how much money | | | 16 | it cost? | | | | 17 | A | Probably more that \$1 million. | | | 18 | ੁ | Does \$1.37 million sound about right? | | | 19 | A | I'm not sure. | | | 20 | ு | And does the approximate purchase date of | | | 21 | | September, 2019 sound about right to you? | | | 22 | A | Not sure. | | | 23 | 0 | Turning back to 373 Taconic for a moment. | | | 24 | | How much was that property purchased for? | | | 25 | A | Probably 400 to 500,000. | |

Fiore Reporting and Transcription Service, Inc.

| | Ho Wan Kwok - April 6, 2022 105 | |----|----------------------------------------------------| | 1 | THE PRIVATE INTERPRETER: No, no, no. | | 2 | THE OFFICIAL INTERPRETER: 4 to 5 million. | | 3 | I'm sorry. | | 4 | Q Approximate time of purchase of 373 | | 5 | Taconic, if you know? | | 6 | A I don't know. | | 7 | Q Have you ever resided at 33 Ferncliff? | | 8 | A No. | | 9 | Q Do you know whether anyone currently lives | | 10 | there? | | 11 | A Before there is another comrade maybe, you | | 12 | know, for disjoined Chinese Communist Party and he | | 13 | was to live there. | | 14 | Q How long ago? | | 15 | A Probably one to two years ago. | | 16 | Q Do you remember that person's name? | | 17 | A Yes. | | 18 | Q What is it? | | 19 | A Wong Din Gong (ph). | | 20 | Q Does anyone currently live there, if you | | 21 | know? | | 22 | A I don't know. | | 23 | Q Talking about 373 Taconic, where did the | | 24 | money come from to purchase that property? | | 25 | A I don't know. |

Fiore Reporting and Transcription Service, Inc.

| | | Ho Wan Kwok - April 6, 2022 | 106 | |----|---------------------------|------------------------------------------------------|-----| | 1 | Q | Do you know whether the house was | | | 2 | | purchased with cash or financing? | | | 3 | A | I don't know. | | | 4 | Q | Same questions for 33 Ferncliff. Do you | | | 5 | | know where the money came from to purchase that | | | 6 | | house? | | | 7 | A | I heard it was purchased by cash. | | | 8 | Q | From whom -- sorry. From whom did you hear | | | 9 | | that? | | | 10 | A | I don't remember. | | | 11 | Q | Do you know where that money came from? | | | 12 | A | I don't know. | | | 13 | Q | Do you know what Saraca Media Group is? | | | 14 | A | Saraca? | | | 15 | Q | Saraca. | | | 16 | A | Saraca Media Group. I do. | | | 17 | Q | What is Sirraca Media Group? | | | 18 | A | Just Saraca. It's a company. | | | 19 | Q | What kind of company? | | | 20 | A | I'm not sure. | | | 21 | Q | Have you ever had any relationship with | | | 22 | | Saraca personally? | | | 23 | A | No. | | | 24 | Q | Do you know anything about the type of | | | 25 | | business that Saraca conducts? | | | | | Ho Wan Kwok - April 6, 2022 107 | | | 1 | A | I remember they are related to GTV Media | | | 2 | | platform, or they invested on the GTV Media | | | 3 | | platform. | | | 4 | Q | How do you know that? | | | 5 | A | Because I was their consultant, who owned | | | 6 | | the consultant. And also I was the GTV host. And | | | 7 | | also this is one of the input and platform for | | | 8 | | disjoined communist party. | | | 9 | Q | When you said you were a consultant a | | | 10 | | moment ago was that for Saraca or for GTV? | | | 11 | A | GTV. | | | 12 | Q | Has Saraca ever been -- ever had the 162 | | | 13 | | East 64th Street address associated with it? | | | 14 | THE OFFICIAL INTERPRETER: | Which address? | | | 15 | | Can you repeat that one. | | | 16 | Q | Yes. 162 East 64th Street. The question | | | 17 | | is whether Saraca has ever been associated with that | | | 18 | | address? | | | 19 | A | I don't know. | | | 20 | Q | That is the family office address, | | | 21 | | correct? | | | 22 | A | It's one of them. | | | 23 | Q | Where are the other ones? | | | 24 | A | I don't know. | | | 25 | Q | Are there any others in New York City? | |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 108 1 I just want to clarify. Golden Spring is A 2 one of the companies in this building, 162. Understood and thank you. က ೧ ರ್ ರ We've referred to the family office during 5 your questioning and I just want to be clear. When we talk about the family office are we referring to ﯼ 7 that address on East 64th Street? 8 A Yes . Has GTV ever been associated with the ி Q family office address? 10 11 A I don't know. 12 Q Who owns Saraca? 13 A My son. 14 ್ Since when? 15 A I don't know. Does Saraca currently exist? 16 റ്റ I don't know. 17 ದ 18 O Do you have any idea how many -- do you 19 | know anything about the value of Saraca's assets? I don't know. 20 A Do you know anything about payments Saraca 21 റ്റു 22 has made to GTV? No, I don't know. 23 A 24 Has your wife ever told you about any റ്റ് 25 1 multi-million dollar payments from Saraca to

| Ho Wan Kwok - April 6, 2022 109 | | |------------------------------------------------------------------|------------------------------------------------------| | 1 | Greenwich Land? | | 2 | A I don't know. | | 3 | Q You don't know whether he's ever told you | | 4 | or you don't know about the payments? | | 5 | A She never told me and I don't even know | | 6 | how much. | | 7 | Q Do you know a company called Ziba Limited, | | 8 | Z-I-B-A? | | 9 | THE OFFICIAL INTERPRETER: Ziba, Z-I-B-A? | | 10 | MR. HARBACH: Yes. | | 11 | A I don't know. | | 12 | Q I'm sorry if I've already asked this. | | 13 | What is the relationship, if any, between Saraca and | | 14 | GTV? | | 15 | A Saraca is the investor for GTV. | | 16 | Q Do you know how much money Saraca invested | | 17 | in GTV? | | 18 | A I don't know. | | 19 | Q When was GTV founded? | | 20 | A 2020. Maybe 2019. Not very sure. | | 21 | Q Do you know the names of any of the | | 22 | officers or directors of Saraca? | | 23 | A I don't know. | | 24 | Q Do you know whether Yvette Wang is an | | 25 | officer or director of Saraca? |

Fiore Reporting and Transcription Service, Inc.

| | | Ho Wan Kwok - April 6, 2022 | 110 | |----|---|-----------------------------------------------------|-----| | 1 | A | I don't know. | | | 2 | Q | Do you know someone called Hong Chung | | | 3 | | Wang? | | | 4 | A | Yes. | | | 5 | Q | Who is that? | | | 6 | A | He's my partner and also comrade for | | | 7 | | disjoined Communist Party. | | | 8 | Q | Is he a friend of yours? | | | 9 | A | Friend, comrade and a partner. | | | 10 | Q | What do you mean by partner? | | | 11 | A | Because we had a business corporation. | | | 12 | Q | Tell me about that. | | | 13 | A | Well, I don't remember the name of that | | | 14 | | company. It's a company for investigating Communist | | | 15 | | Party in USA doing money laundering and committing | | | 16 | | crimes. | | | 17 | Q | Was it a for profit company? | | | 18 | A | I don't know. | | | 19 | Q | You don't know? | | | 20 | A | I don't know. | | | 21 | Q | What was the name of the company? | | | 22 | A | I don't remember when getting to English. | | | 23 | | I don't remember the name. | | | 24 | Q | Approximately what time frame where you | | | 25 | | partners with Hong Chung Wang in this company? | | | | | Ho Wan Kwok - April 6, 2022 111 | | | 1 | A | I don't remember. | | | 2 | Q | Within the last three years? | | | 3 | A | It must be more than three years ago. | | | 4 | Q | More than ten years? | | | 5 | A | No. | | | 6 | Q | Did Hong Chung Wang ever have any | | | 7 | | connection to Saraca? | | | 8 | A | I don't know. | | | 9 | Q | Was he ever an officer or director of | | | 10 | | Saraca? | | | 11 | A | I don't know. | | | 12 | Q | What does the G in GTV stand for? | | | 13 | A | God. The Goal, like in -- G-O-A-L. | | | 14 | Q | The English word "goal"? | | | 15 | A | Yea. Goal or God. | | | 16 | Q | Okay. How long have you known Hong Chong | | | 17 | | Wang? | | | 18 | A | I don't remember. | | | 19 | Q | More than ten years? | | | 20 | A | Roughly. | | | 21 | Q | And do you still consider him a friend | | | 22 | | today? | | | 23 | A | Yes. | | | 24 | | MR. HARBACH: Just a moment, please. | | | 25 | Q | There's been many questions today about | |

Fiore Reporting and Transcription Service, Inc.

ge 112 of 134

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 112 1 Golden Spring funding your living expenses. 2 Is it correct that as far as your living ന expenses are concerned that none of that is expected র্ব to be repaid? ഗ Yes, true. A And so those monies are not the subject of ဖ 0 7 any formal agreement, correct? 8 A No . တ Q And those monies essentially then are a 10 gift to you, correct? A 11 Yes . What's the Rule of Law Foundation? 12 O 13 A What does that mean? The question is what is it? 14 ್ತ THE OFFICIAL INTERPRETER: The Rule of Law 15 Foundation? 16 17 MR. HARBACH: Yes, sir. 18 THE OFFICIAL INTERPRETER: I didn't get it. Can you ask it another way? 19 1 There's an entity called --20 റ്റു THE OFFICIAL INTERPRETER: Oh. 21 22 -- the Rule of Law Foundation. O 23 THE OFFICIAL INTERPRETER: Okay. MR. HARBACH: I'll hopefully save some 24 25 { time by just asking this question instead.

Ho Wan Kwok - April 6, 2022 113

1 Q Are you familiar with the Rule of Law 2 Foundation? 3 A Yes. 4 Q Were you involved in its establishment? 5 A Yes. 6 Q Did you contribute any money to it when it 7 was formed? 8 A Not myself. 9 Q Did you direct any entity to contribute to 10 the Rule of Law Foundation? 11 A Suggestion in a direct and suggesting any 12 difference -- 13 Q If there was a suggestion, please tell me 14 it was a suggestion. 15 A I didn't direct anybody or order anybody. 16 I just always suggest people to make donations for 17 the Foundation. 18 THE PRIVATE INTERPRETER: As an 19 interpreter, I think that if the witness is asking 20 the interpreter questions, the interpreter should 21 interpret the question asked by the witness instead 22 of answer that question. 23 THE OFFICIAL INTERPRETER: I can answer 24 anything. 25 THE PRIVATE INTERPRETER: The witness said

*Fiore Reporting and Transcription Service, Inc.*

| 1 | are you talking about the (indiscernible) -- | | |----|----------------------------------------------------|-----| | 2 | THE OFFICIAL INTERPRETER: That's why I | | | 3 | relayed the questions to the attorney. | | | 4 | THE PRIVATE INTERPRETER: You answer him | | | 5 | yes, and then you say that. | | | 6 | THE OFFICIAL INTERPRETER: Oh, for God's | | | 7 | sake. I didn't say -- did I miss anything? | | | 8 | (Interpretation.) | | | 9 | THE OFFICIAL INTERPRETER: Okay. No | | | 10 | question. He said no question was not answered. | | | 11 | BY MR. HARBACH: | | | 12 | Q Did you ever suggested to any of your | | | 13 | family members that they donate to the Rule of Law | | | 14 | Foundation? | | | 15 | A Yes, I did suggest. | | | 16 | Q Did any of your family members or the | | | 17 | family controlled enterprises contribute money to | | | 18 | the Rule of Law Foundation? | | | 19 | A Yes. | | | 20 | Q How much money? | | | 21 | A For cash there is one -- over \$1 million. | | | 22 | From Hong Kong, Japan and Mainland -- in | | | 23 | China and all combined it should be more than 30 | | | 24 | million. | | | 25 | Q And just focusing for the moment on | | | | Ho Wan Kwok - April 6, 2022 | 115 | | 1 | contributions from your family at your suggestion. | | | 2 | Approximately, how much money is that? | | | 3 | A I don't know the details. Because of | | | 4 | security reasons they don't want me to know. | | | 5 | Q Did you say a moment ago that your family | | | 6 | contributed over a million dollars? | | | 7 | A One million cash is in New York here. | | | 8 | Q When was that? | | | 9 | A I don't remember. | | | 10 | Q Is the reason -- well, let me ask it this | | | 11 | way. Did you suggest an amount to your family | | | 12 | members that they should contribute to the Rule of | | | 13 | Law Foundation? | | | 14 | A I want them to donate the more the better. | | | 15 | Q Is that what you told them? | | | 16 | A Yes. | | | 17 | Q Do you know whether the Rule of Law | | | 18 | Foundation is associated with the family office | | | 19 | address on 64th Street? | | | 20 | A Yes. | | | 21 | Q Did you ever make a \$100 million donation | | | 22 | to the Rule of Law Foundation in November of 2018? | | | 23 | THE OFFICIAL INTERPRETER: Can you repeat | | | 24 | that again? | | | 25 | Q Did you ever make a \$100 million donation | |

Fiore Reporting and Transcription Service, Inc.

04/30/24 Pag

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 116 1 to the Rule of Law Foundation in November, 2018? 2 No. In the live stream like I want --A tried to collect the funds, in the live stream show. က 4 Q Did you ever --5 MR, BALDIGA: Wait. Was that his whole 6 answer? THE OFFICIAL INTERPRETER: Yeah. Something 7 8 wrong? ் THE PRIVATE INTERPRETER: Not quite exactly what the witness said. 10 (Indiscernible) broadcasting is okay. 11 12 | Live stream is okay. But collect money --13 THE OFFICIAL INTERPRETER: Asking for 14 donation, right? 15 (Interpretation) THE PRIVATE INTERPRETER: Raise --16 THE WITNESS: Raising money, raise 17 18 donations. Yeah, in the live stream broadcast thing, or whatever, you know, asking for donations 19 to -- you know, to raise funds, to raise money. 20 Did you ever promise to donate \$1 billion 21 22 to the Rule of Law Fund? THE OFFICIAL INTERPRETER: 10 billion you 23 said? 24 MR. HARBACH: No, sir. 1 billion. 25

Ho Wan Kwok - April 6, 2022 117

THE OFFICIAL INTERPRETER: Oh, one billion. A I don't remember. I don't remember. Q Do you mean that it's possible that you made that promise? A So we could reach that goal if we combine the organizations all over the world. Q Understand. And it's a simple question. I just don't know the answer. Did you yourself ever promise to donate \$1 billion to the Rule of Law fund? A In the past five years I did the live stream over 5,000 times. Some of the live stream could have reached four or five hours. It's hard for me to remember every sentence I said. Q Well, I understand that, but I'm only asking about one issue. And it is whether you ever promised publicly, or privately or anyhow to donate \$1 billion to the Rule of Law Fund? THE PRIVATE INTERPRETER: He did not say invest. MR. HARBACH: Donate THE OFFICIAL INTERPRETER: Yeah, donate. A I don't remember. Q I'll ask this one one more time.

*Fiore Reporting and Transcription Service, Inc.*

| | Ho Wan Kwok - April 6, 2022 118 | |----|------------------------------------------------------| | 1 | Are you saying that it is possible that | | 2 | you made such a promise. You just can't be sure? | | 3 | A In front of Ms. Holley I wouldn't say | | 4 | anything is possible but this is a very serious | | 5 | issue. Now they start the scheme again. | | 6 | Q Well, this isn't what did you have for | | 7 | breakfast three days ago. This is did you promise | | 8 | to donate \$1 billion and if the answer is you don't | | 9 | know, that's okay. | | 10 | MR. BALDIGA: I think that's what the | | 11 | answer has been. | | 12 | MR. HARBACH: No, the answer has been I | | 13 | don't remember. | | 14 | MR. BALDIGA: Don't remember. | | 15 | MR. HARBACH: Yes, sir. That's a little | | 16 | different. | | 17 | Q So the answer might be no, but you're not | | 18 | saying no. You're saying you don't remember. | | 19 | A I said it three times, I don't remember. | | 20 | MR. BALDIGA: There's no question -- | | 21 | A Because in the past five years | | 22 | (indiscernible) always making these kind of answers | | 23 | for me so that's why the judge from the South | | 24 | District were fooled by you and you started again -- | | 25 | Q I'll move on. | | | Ho Wan Kwok - April 6, 2022 119 | | 1 | A In the South District court I only met | | 2 | judge 20 seconds. I didn't say one sentence within | | 3 | this five years and I was fined a total about \$300 | | 4 | million because that's what they did. | | 5 | MR. BALDIGA: All right. Let's stop it. | | 6 | Let's wait for a question and we'll answer the | | 7 | question. | | 8 | MR. HARBACH: Bill, I appreciate your | | 9 | patience. I'll move on. | | 10 | MR. BALDIGA: Translate what I said, | | 11 | please. | | 12 | THE OFFICIAL INTERPRETER: Can you repeat | | 13 | that? Everybody's saying at the time. | | 14 | MR. BALDIGA: Ask a question and he'll | | 15 | answer a question. | | 16 | Q Have you made any donations to the Rule of | | 17 | Law Foundation in the last two years? | | 18 | A Myself, right? | | 19 | Q Yes, sir. | | 20 | A No. | | 21 | Q Have you suggested to any of your family | | 22 | that they make donations to the Rule of Law | | 23 | Foundation within the last two years? | | 24 | A I don't remember. | | 25 | Q Would you ever have made a promise to |

Fiore Reporting and Transcription Service, Inc.

Document 312-2

ge 120 of 134

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 120 donate \$1 billion to the Rule of Law Foundation if 1 you did not actually have that money? 2 MR. BALDIGA: Objection to form. 3 THE OFFICIAL INTERPRETER: I didn't get ਪੁੱ it. Can you repeat one more time. ട Would you have ever made a promise to 6 o donate \$1 billion to the Rule of Law Foundation if 7 you did not actually have that money. 8 MR. BALDIGA: And I objected. 9 MR. HARBACH: And then Bill objected. 10 THE OFFICIAL INTERPRETER: He said are you 11 --- want to sentencing me to death sentence? 12 Approximately how much is the Lady May 13 Q 14 worth? I don't know. 15 A Over the years that you have been aboard 16 റ്റു the Lady May, approximately how many times have you 17 invited friends to join you? 18 THE OFFICIAL INTERPRETER: Can you repeat 19 that question one more time? 20 MR. HARBACH: Yes. 21 Over the years that you had been aboard 22 the Lady May, approximately how many times have you 23 invited friends out to join you? 24 Hold on. 25 MR. BALDIGA:

| | Ho Wan Kwok - April 6, 2022 121 | |----|-----------------------------------------------------| | 1 | MR. HARBACH: Sorry, Bill. | | 2 | MR. BALDIGA: David, you have a deposition | | 3 | on the Lady May issues coming up. You can choose | | 4 | today or then. Either one is fine. | | 5 | MR. HARBACH: That's a fair point. I'll | | 6 | move on. | | 7 | MR. BALDIGA: Okay. No question. | | 8 | MR. HARBACH: If I could direct counsel's | | 9 | attention again to document 77. And I want to focus | | 10 | on question 19. | | 11 | Q Mr. Kwok, let me know when you're read | | 12 | that question. It's no. 19. | | 13 | (Pause.) | | 14 | A Finished. | | 15 | Q Okay. So for the benefit of the record, | | 16 | the question says within ten years before you filed | | 17 | for bankruptcy did you transfer any property to a | | 18 | self settled trust or similar device of which you | | 19 | are a beneficiary? | | 20 | A No. | | 21 | Q And that is indeed what you checked on the | | 22 | form. My question for you is if you turn -- if | | 23 | changed the word you to a family member as the | | 24 | beneficiary, what would the answer be? | | 25 | MR. BALDIGA: Objection. |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 122 1 A I cannot answer questions with if. 2 Q I'll ask it a different way. ന MR. HARBACH: And, Jack, I'll ask you to 4 bear with me. Within ten years before you filed for 5 O 6 bankruptcy did you transfer any property to a self settled trust or similar device of which a member of 7 8 your family is a beneficiary? 9 A No . Sticking with that same document going 10 o forward to question 27. Just let me know when 11 you're read it, sir. 12 13 (Pause.) A Okay. I'm finished. 14 So you see there you have checked the box 15 ു next to the word yes. And then the instructions say 16 17 check all that apply above and fill in the details 18 below for each business. MR. HARBACH: Do you see where that is, 19 20 Jack? THE OFFICIAL INTERPRETER: I didn't see 21 22 that. MR. HARBACH: Next -- Holley can show you. 23 24 (Pause.) MR. HARBACH: So I was just pointing out 25

| Ho Wan Kwok - April 6, 2022 123 | | |---------------------------------|------------------------------------------------------| | 1 | to the witness -- for the benefit of the translator | | 2 | I'll say it again. | | 3 | Q Next to the box that is checked yes, the | | 4 | instructions say check all that apply above and fill | | 5 | in the details below for each business. None of the | | 6 | boxes above is checked and that's my question. | | 7 | Which box or boxes should be checked for | | 8 | each of those three entities that you have listed? | | 9 | A I cannot determine which one. | | 10 | Q Is that something you would need more time | | 11 | to figure out or you just don't know the answer? | | 12 | A I could answer one by one. | | 13 | Q Okay. Let's do that. Let's start with | | 14 | Genever. | | 15 | A Which Genever? | | 16 | Q Well, the one that's listed is Genever | | 17 | Holdings Corporation. | | 18 | Which of those boxes would you check for | | 19 | Genever Holdings Corporation, if any? | | 20 | A It was one time -- it was a member of LLC. | | 21 | The above don't apply and should transfer to no. 12 | | 22 | -- transfer to 12. | | 23 | It used to be an LLC. | | 24 | Q Are you saying that you would check the | | 25 | box for a member of an LLC but it should be in the |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 124 1 past tense? 2 Used to be. A Yes. က Do any of the other boxes apply to your ੁ বা relationship to Genever Holdings Corporation? ട് The last row seems like appropriate for A ပ me. I'm not very sure. The last row being an owner of at least 7 ପ five percent of the voting or equity securities of a ထ ಿ corporation? I owned 50 percent for a very short period 10 A of time. 11 12 Okay. What about for Shiny Time? o 13 A Shiny Time already went away. I understand. When it was in existence, 14 റ്റ which of those boxes was accurate? 15 | A 16 Number one. 17 0 A sole proprietor? 18 A Yes . 19 Q Any of the others? 20 ದ್ Not sure. Okay. What about for Well Origin Limited? 21 റ്റ 22 A It went away. Okay. Same question though. Which of 23 റ്റ those boxes applied when it was in existence? 24 25 A Number one.

| Ho Wan Kwok - April 6, 2022 125 | | |---------------------------------|------------------------------------------------------| | 1 Q | Any of the others? | | 2 A | Not sure. | | 3 Q | One last point about this question. | | 4 | For Genever Holdings Corporation the block | | 5 | for the dates that the business existed is blank. | | 6 Q | Do you know what those dates should be? | | 7 A | 2015. Probably March, April to June, | | 8 | July. | | 9 Q | Of which year? | | 10 A | 2015. | | 11 Q | So from approximately March or April until | | 12 | approximately July all in 2015? | | 13 A | Yes. | | 14 Q | Okay. And is that the entire duration | | 15 | that that corporation existed? | | 16 A | I was in the company for a few months, for | | 17 | this period of time, a few months and with holding - | | 18 | - in stock holding. And the company still existed | | 19 | after I left. | | 20 Q | I understand. And does it still exist | | 21 | today? | | 22 A | I believe it still exists. | | 23 Q | Okay. In what year did you get married? | | 24 A | 1918 -- or 1985. | | 25 Q | What year was your son born? |

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 126 1 1986. A 2 Q And how old are you, sir? 3 ಗಿ 54 . How old was your son when your family 4 റു began working with Uda Property Company? 5 ర్ 11. Oh, five years -- five years old. A And so that would have been in 7 ் approximately 1991 that your family began working 8 9 with Uda? 10 A Yes . When was the Henan Uda Hotel completed? 11 ் 12 A In 1997. And what about the Uda International Trade 13 റ്റ് When was it completed? 14 Center. 15 A At pretty much the same time. In your declaration in this case you 16 റ്റ stated that both of those were successful ventures. 17 18 A Yes. That allowed your family to start amassing 19 Q 20 significant wealth. A Yes . 21 22 So recognizing that this is in the early ্ '90's how much money approximately did those 23 ventures bring to your family? 24 25 A I don't remember.

12-2 Filed 04/30/2

| | Ho Wan Kwok - April 6, 2022 127 | |----|--------------------------------------------------| | 1 | Q More than \$50 million? | | 2 | THE OFFICIAL INTERPRETER: 50 or 15? | | 3 | MR. HARBACH: 5-0. | | 4 | THE OFFICIAL INTERPRETER: Oh, okay. | | 5 | A I don't remember. | | 6 | Q What about the Pengu Plaza? When was it | | 7 | completed? | | 8 | A July 2008. | | 9 | Q So between the early '90's and 2008 what | | 10 | other projects of significant did the Guo family | | 11 | invest in or participate in? | | 12 | THE OFFICIAL INTERPRETER: Since 1990's to | | 13 | -- | | 14 | A Between the early 1990's and 2008. | | 15 | Q Do you remember any of them? Any of the | | 16 | significant ventures? | | 17 | A Beijing Golden Spring. | | 18 | Q What was that? | | 19 | A It's a property company. Real estate. | | 20 | It's a real estate company. | | 21 | Q Was this a development company or a -- | | 22 | like a buying and selling agency? | | 23 | A Developing company. | | 24 | Q When was the Pangu Plaza project started, | | 25 | approximately? |

Fiore Reporting and Transcription Service, Inc.

128 Ho Wan Kwok - April 6, 2022 1 A Roughly 1999. 2. Okay. So let's use that as a point in ್ ന time. 4 At the beginning of the Pangu Plaza ഗ project approximately how much had the family 6 amassed in wealth? 7 THE PRIVATE INTERPRETER: Ask that ന question again? ் MR. HARBACH: Sure. Q As of 1999, which was the beginning of the 10 Pangu Plaza project, approximately how much wealth 11 had the family earned or amassed by that time? 12 -THE OFFICIAL INTERPRETER: You're talking 13 ਹੈ ਕੇ about after 1999? MR. HARBACH: No, I'm talking about as of 15 1999? 16 THE OFFICIAL INTERPRETER: Oh, as of 1999. 17 How much money had the family made by 18 ್ತ 1999? 19 T don't remember. 20 A More than \$100 million? 21 Q I don't remember. 22 A More than \$500 million? 23 ੁ A I don't remember. 24 More than a billion dollars? 25 റ്റു

Ho Wan Kwok - April 6, 2022 129 1 A I don't remember. 2 Q Were you personally involved in the work 3 with Uda Property Company? 4 A Yes. 5 Q Were you personally involved in the 6 development of the Henan Uda Hotel? 7 A Yes. 8 Q Were you personally involved in the Uda 9 International Trade Center in Zhengzhou? 10 A Yes. 11 Q Were you personally involved in the 12 development of the Pengu Plaza? 13 A Yes. 14 Q Who was in charge of the Beijing Golden 15 Spring Real Estate Development firm? 16 A A professional group. 17 Q Were you a member of that group? 18 A At that time I was a consultant. 19 Q For Beijing Golden Spring? 20 A Yes. 21 Q During what time frame was that, 22 approximately that you were a consultant for them? 23 A After 2000. 24 Q After 2000. Okay. 25 MS. CLAIBORN: Mr. Harbach, I just want to

Fiore Reporting and Transcription Service, Inc.

Ho Wan Kwok - April 6, 2022 130 note that it is 4:18 and I know we've had a long day 1 2 -- and I wanted to give -- I apologize for interrupting you, first of all. ന ব MR. HARBACH: That's all right. MS. CLAIBORN: But I wanted to give 5 counsel for the committee a chance to ask a few 6 questions today before we conclude. 7 MR. HARBACH: Of course. Sure. ന ் MR. STAFSTROM: I'll be very brief. EXAMINATION BY MR. STAFSTROM: 10 I noticed your hair is very short. I like 11 o it. Have you gotten a haircut recently? 12 | 13 A Yes. I had a haircut. Where did you get it cut? 14 റു 15 A My wife. Oh, your wife. Okay . 16 റു Does she always cut your hair? 17 18 A After the virus until now. Okay. All right. I have no further 19 o 20 questions then. MS. CLAIBORN: I'm going to put the 21 22 | recording on pause while we work on selecting a new 23 date. (Off the record.) 24 MS. CLAIBORN: We're back on the record 25

Document 312-2

e 132 01 134

Ho Wan Kwok - April 6, 2022 131 after a short break. We have selected a continuance date of April 29th, beginning at 10:00 a.m. We are concluded for today. Thank you. (Meeting adjourned.)

Fiore Reporting and Transcription Service, Inc.

1 I, CHRISTINE FIORE, court-approved 2 transcriber and certified electronic reporter and 3 transcriber, certify that the foregoing is a correct transcript from the official electronic sound বা 5 recording of the proceedings in the above-entitled 6 matter.

Christine Fiore

April 15, 2022

132

10 11

। ਪੈ

1 9

Transcriber

Christine Fiore, CERT

| Ho Wan Kwok - April 6, 2022 | | 133 | |-----------------------------|------------------------------|------| | 1 | | | | 2 | INDEX | | | 3 | | Page | | 4 | Examination by Ms. Claiborn | 6 | | 5 | Examination by Mr. Wolman | 71 | | 6 | Examination by Mr. Harbach | 80 | | 7 | Examination by Mr. Stafstrom | 130 | | 8 | | | | 9 | | | | 10 | | | | 11 | | | | 12 | | | | 13 | | | | 14 | | | | 15 | | | | 16 | | | | 17 | | | | 18 | | | | 19 | | | | 20 | | | | 21 | | | | 22 | | | | 23 | | | | 24 | | | | 25 | | |

Fiore Reporting and Transcription Service, Inc.

CONFIDENTIAL CONFIDENTIAL