郭文贵刑事案 · ECF #841

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a. amend the Preliminary Forfeiture Order to exclude the property ($6,000,000, plus interest) in which Petitioner has a superior right, title, and interest as an innocent third party or a bona fide purchaser for value; b. alternatively, grant Petitioner a hearing pursuant to 21 U.S.C. § 853(n), along with such discovery, including but not limited to discovery pertaining to Defendants' fraudulent conduct in connection with the Himalaya Exchange and Petitioner's investment in the Exchange, as may be appropriate; c. alternatively, in the event that this Petition is denied, order that the Petitioner be compensated through the MNF's remission process, as set forth in the Government's submission to the Court, Dkt. 785, letter; and d. order such other and further relief as the Court deems just and proper. Dated: April 27, 2026 Respectfully Submitted, FORD O'BRIEN LANDY LLP By/-0- Kevin J. O'Brien 275 Madison Avenue, 24th Floor New York, NY 10016 Tel: (212) 858-0040 (main) kobrien@fordobrien.com Attorney for Petitioner 1328777 B.C. Ltd

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