发言原文
When structuring your motions or objections, you can cite these major federal precedents to demonstrate that the government cannot satisfy the alter-ego test with mere operational control: 1. William Passalacqua Builders, Inc. v. Resnick Developers South, Inc., 933 F.2d 131 (2d Cir. 1991) This is the foundational Second Circuit case governing alter-ego and veil-piercing claims. The Rule: The court explicitly ruled that to pierce the corporate veil under an alter-ego theory, the claiming party must prove that the owner exercised "complete domination" over the entity. Application: Domination means the corporation had "no separate mind, will or existence of its own." If other third parties (like Wei Lihong or separate farm managers) were independently moving millions of dollars out of the corporate account or controlling physical assets for public broadcasting, the entity maintained a functional existence outside of the Defendant's "complete domination." 2. First National City Bank v. Banco Para el Comercio Exterior de Cuba (BANCEC), 462 U.S. 611 (1983) The U.S. Supreme Court addressed the exact threshold of control required to treat separate corporate entities as a single monolith