郭文贵刑事案 · PETITION · ECF #652

| UNITED STATES DISTRICT COURT SOUTHERN<br>DISTRICT OF NEW YORK | PETITION UNDER FED. R. CRIM. P. 32.2 AND 21<br>U.S.C. § 853(n) FOR ADJUDICATION OF<br>PETITIONER'S RIGHT TO SPECIFIC PROPERTY OF | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------| | ---------------------------------------- X | [\$70,168.00] | | UNITED STATES OF AMERICA | | | - V. - | S1 23 CR 118 (AT) | | HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles<br>Kwok," a/k/a "Guo Wengui," a/k/a "Brother<br>Seven," a/k/a "The Principal," KIN MING JE, a/k/a<br>"William Je," and YANPING WANG, a/k/a "Yvette," | | | Defendants. | | | ---------------------------------------- X | |

I, Lingli Li (the "Pecconer"), pursuant to 21 U.S.C. § 853(n) and Rule 32.2(c) of the Federal Rules of Criminal Procedure, herby respecgully peccons the Court for a determinacon of the Pecconer's interest in specific property subject to the Court's Consent Preliminary Order of Forfeiture as to Specific Property/Money Judgment, signed by Your Honor on January 6, 2025 and entered on January 7, 2025, (the "Forfeiture Order") which includes various bank accounts ("Forfeited Accounts"), Dkt. 488, to exclude all property in which the Pecconer has right, ctle, and interest, namely, \$70,168.00 (the "Property"). In support hereof, the Pecconer states as follows:

1. Between 2020 to 2021, I, the Pecconer wired \$70,168.00 in total to parccipate in the projects.

2. I, the Pecconer transferred U.S. currency to the Forfeited Accounts as below :

3. On October 14, 2020- wired \$20,000.00 to Maywind LLC, a recipient of then Pheonix farm, for Farm loan project, Transaccon number is: 52684403 Upon informacon and belief, these funds were seized by the government among potencally Forfeited Accounts and assets.

4. On November 19, 2020- wired \$1,020.00 to Maywind LLC, a recipient of then Pheonix farm, for Farm loan project, Transaccon number is: 5264829448 Upon informacon and belief, these funds were seized by the government among potencally Forfeited Accounts and assets.

5. On November 19, 2020- wired \$1,064.00 to Maywind LLC, a recipient of then Pheonix farm, for Farm loan project, Transaccon number is: 5268544986 Upon informacon and belief, these funds were seized by the government among potencally Forfeited Accounts and assets.

6. On September 4, 2021 – wired \$30,000.00 to Maywind LLC, a recipient of then Pheonix farm, for Farm loan project, Wire transfer number is: XXXXXXXX Upon informacon and belief, these funds were seized by the government among potencally Forfeited Accounts and assets. (Recipient Account Name: Medical supply System Internaconal; Account Number: 69233779; Street Address: 12810 N Cave Creek Rd Apt.234, Phoenix, AZ, 85032, USA

Receiving Bank Name: Wells Fargo Bank, Naconal Associacon; Street Address: 1000 Louisiana St.)

7. On March 11, 2021 – wired \$18,084.00 to Superior Financial Associates INC, a recipient of then Mayflower farm, for Farm loan project, Wire transfer number is: XXXXXXXX Upon informacon and belief, these funds were seized by the government among potencally Forfeited Accounts and assets. (Recipient Name: Superior Financial Associates INC; Account Number: 898122702090; Address: 115 W 42ND ST, ONE BRYANT PARK NEW YORK CITY, NY 10036 US)

| Transaction Type | Wire number | Total Amount | Payment Method | Recipient | Asset ID | |------------------|-----------------------------------|--------------|----------------|-------------|-----------------| | Farm Loam | Transaction number is: 52684403 | \$20,000 | Wiring | Maywind LLC | Pheonix<br>Farm | | | Transaction number is: 5264829448 | \$1,020 | Wiring | | | | | Transaction number is: 5268544986 | \$1,064 | Wiring | | | | | Account Number: 69233779 | \$30,000 | Wiring | | |

| Transaction<br>Type | Wire number | Total Amount | Payment<br>Method | Recipient | Asset ID | |---------------------|---------------------------------|--------------|-------------------|--------------------------------------------|-------------------| | Farm Loan | Account Number:<br>898122702090 | \$18,084.00 | Wiring | Superior<br>Financial<br>Associates<br>INC | Mayflower<br>Farm |

6. I the pecconer never received any funds or investment back from the investments before they were seized by the government, having now suffered a total of unrecovered funds of my \$120,030.00 investment.

7. I, the pecconer, was not consulted prior to the entry of the Forfeiture Order. Pecconer had no knowledge that Defendant Wang consented to forfeit the Property. I invested in G|CLUBS to support the Whistleblower Movement which is led by Miles Guo. I believe that Mr. Guo is an honest person. He is simply doing the right thing to take down the CCP.

8. As an owner of the above listed assets, I, the pecconer, has an interest in the Property which Defendant Wang had no authority to agree to forfeit. Rather, Pecconer has a superior interest in the Property which cannot be the subject of the Forfeiture Order relacng to Defendant Wang.

9. I was not involved in, nor did I have any knowledge of the Defendants' accvices. Accordingly, I am also an innocent third party pursuant to 21 U.S.C. § 853(n). Any third party "assercng a legal interest in property which has been ordered forfeited to the United States pursuant to this seccon may... peccon the court for a hearing to adjudicate the validity of his alleged interest in the property." 21 U.S.C. § 853(n)(2). The peccon, which is sworn and signed by the me, "shall set forth the nature and extent of the pecconer's right, ctle, or interest in the property, the cme and circumstances of the pecconer's acquisicon of the right, ctle, or interest in the property, and addiconal facts supporcng the pecconer's claim, and the relief sought." Id. § 853(n)(3).

10. Here, I, the pecconer is the lawful owner of the Property.

11. Alternacvely, Pecconer is a bona fide purchaser for value of my interest in the Property under 21 U.S.C. § 853(n)(6)(B).

12. Pecconer was made aware of the Order of Forfeiture by viewing it at www.forfeiture.gov (which was published from February 6, 2025 through March 7, 2025) nocng that: "pursuant to Title 21, United States Code, Seccon 835(n), persons other than the defendant who wish to assert a legal interest in property that has been ordered forfeited to the United States must file a peccon for a hearing to adjudicate the validity of their alleged interest in the property with the Court within thirty (30) days of the final publicacon of nocce, or receipt of actual nocce, whichever is earlier."

13. Pecconer has filed this peccon within 60 days of the inical publicacon of nocce.

WHEREFORE, Pecconer respecgully requests and peccons this Court: a. to amend the Forfeiture Order to exclude the Property in which Pecconer has a righgul interest as an innocent third party, superior interest, and/or a bona fide purchaser for value. b. A hearing pursuant to 21 U.S.C. § 853(n) on any disputed maPers. c. Compensacon for the value of Pecconer's interest if the Peccon is denied; d. Any other relief the Court deems just and proper.

Dated: April 06, 2025

Respecgully SubmiPed,

Lingli Li

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Signatu

## VERIFICATION

I aPest and declare under penalty of perjury that my peccon is not frivolous, and the informacon provided in support of my peccon is true and correct to the best of my knowledge and belief. Executed on April 06, 2025, in Dallas, TX, USA. Phone Number: 352-281-0055

Lingli Li

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Signature