---
type: court_doc
id: "court_2cir_26-1626_dkt_1"
court: "2Cir"
case_no: ""
doc_number: null
doc_type: "DOC"
filed_date: null
lang: "en"
machine_translated: false
url: "https://mubeitech.com/en/court/court_2cir_26-1626_dkt_1"
json_url: "https://mubeitech.com/api/court/court_2cir_26-1626_dkt_1"
---
# Guo Wengui / Miles Guo — appeal · 2Cir ECF 26-1626_dkt_1

**Petition for a writ of mandamus — United States v. Ho Wan Kwok (Miles Guo / Guo Wengui), Second Circuit No. 26-1626, ECF #1 (docketed June 12, 2026; cover letter dated June 9, 2026). Pro se third-party petitioner "Anna" invokes 21 U.S.C. § 853(n), Fed. R. Crim. P. 32.2(c) and 49.1, and the All Writs Act, asking the Second Circuit to order the SDNY district court to docket her repeatedly-rejected "Motion to Subpoena Luc Despins and Key Himalaya Alliance & Farm Personnel" (filed May 22, 2026) and rule on its merits. She claims to be a bona fide G-Series investor entitled to an ancillary forfeiture proceeding, disputes the government's victim/co-conspirator classification framework and Chapter 11 Trustee Luc Despins's unadjudicated "alter ego" theory used to seize the funds, and alleges that Phoenix Farm CEO Wei Lihong transmitted investor records to PRC authorities, coercing witness testimony.**


Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 1 of 61
redar-kct
Date: June 9", 2026
From:
Address:
Telephone:
Email:
To: Clerk of Court
United States Court of Appeals
2ND Circuit
40 Foley Square New York, NY 10007
Re: Petition for Writ of Mandamus
Petitioner: Anna
Case: United States v. Kwok, et al.1 :23-CR-0011 S(AT)
Dear Clerk of the 2"' Circuit Court,
Enclosed please find a Petition for Writ of Mandamus, filed by Ann~ a Pro Se Petitioner in
United States v. Kwok, et al 1 :23-CR-0011 S(AT), under 21 U.S.C. § 853(n), Fed. R. Crim. P. 32.2(c), Fed. R.
Crim. P. 49.1, and 28 U.S.C. § 1651 (a).
Enclosed are:
AFFIDAVIT FOR PERMISSION IN FORMA PAUPERIS
Petition for Writ of Mandamus
Exhibit A-"Motion to Subpoena Luc Despins and Key Himalaya Alliance & Farm Personnel; Evidentiary
Hearing, & Asserting 853(n) Rights, Privacy and Declaration", filed with SDNY District Court on 5/22/2026
Exhibit B - Proofs that the 5/22/26 Motion was sent to the SDNY District Court
Exhibit C - Proof of email request to the District Court for Docketing, dated 5/29/2026
Exhibit D -Proof of email request to the District Court for Docketing, dated 6/2/2026
Exhibit E -Proof of email request "Motion to Compel Docketing" to the District Court, dated 6/5/2026
Respectfully submitted,
.....
Anna

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 2 of 61
Court of Appea\s ,
For The Second C1rcuI1
Tffi m\
JE <C JE TI VIE
United States Court of Appeals1_& JUN 1 2 2026 ill}
for the Second Circuit
BY: - - - """' - - - -
In Re:Anna 3,ct Party in United States v. Kwok, et al. 1 :23-cr-00118-1 (AT),
Petitioner.
PETITION FOR A WRIT OF MANDAMUS RELATING TO THE SDNY DISTRICT COURT
STATEMENT OF JURISDICTION
This Court has authority to issue a writ of mandamus pursuant to the All-Writs Act, 28
U.S.C. § 1651 (a), because the underlying action is "within its appellate jurisdiction".
STANDARD FOR MANDAMUS
To qualify for mandamus relief, a petitioner must demonstrate:
1. A "clear and indisputable" right to the issuance of the writ;
2. That the administrative or judicial officer has a non-discretionary, ministerial duty to
act; and
3. That the petitioner has no other adequate alternative means to attain the desired
relief.
See In re Von Bulow, 828 F.2d 94, 98 (2d Cir. 1987); Cheney v. U.S. Dist. Court for Dist. of
Columbia, 542 U.S. 367, 380-81 (2004).
STATEMENT OF RELIEF SOUGHT
Petitioner is a third party who had filed a "Motion to Subpoena Luc Despins and Key
Himalaya Alliance & Farm Personnel; Evidentiary Hearing, & Asserting 853(n) Rights,
Privacy and Declaration" with the District Court, but the District Court suppresses
Petitioner's legitimate claims and refuses to docket it after Petitioner's multiple requests.
Petitioner has nowhere to go but r~spectfully ask this Court issues a writ directing the
District Court to enter Petitioner's Petition onto the docket and address the underlying
statutory issues on the merits.
STATEMENT OF THE FACTS AND ISSUES
Facts:

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 3 of 61
1) Petitioner is a bona fide, innocent investor who has lawfully invested__..
life savings in the G-series. These funds are currently seized by, or subject to the
constructive custody of, the DOJ, the SEC, Chapter 11 Trustee Luc Despins of Paul
Hastings LLP, or key leaders within the Himalaya Alliance and farms; critically, none
of these assets were retained by, or remain in the custody of, Defendant Kwok.
Accordingly, Petitioner is legally entitled to initiate ancillary proceedings over the
subject property under 21 U.S.C. § 853(n) to vindicate her cognizable legal interest.
2) On May 22nd 2026, Petitioner filed a Motion with the District Court by US mail and
,
email. Afterward, despite Petitioner's repeated requests to the District Court for
docketing, the Motion was suppressed and excluded from the public record without
any stated legal justification, as demonstrated by the correspondence attached
hereto in Exhibit.
Issues:
1) The prosecution's designated victims explicitly testified on the record that they
suffered no cognizable harm or financial injury attributable to the Defendant -The
prosecution's victim classification framework (SDNY Doc. 511) reflects a
systemic collapse of basic forfeiture principles. The prosecution improperly
constructs a closed legal universe where an investor is designated as either a victim
or a co-conspirator, leaving no procedural mechanism for an 853(n) claimant.
Petitioner categorically rejects this flawed taxonomy; the Government cannot
bypass the mandatory ancillary proceeding required by 21 U.S.C. § 853(n) by
imposing an extra-statutory label on innocent third parties.
The Government's victim narrative is fundamentally undermined by the affected
parties themselves. Pursuant to Doc. 834, the ostensible 'victims', 1254 of them,
have formally declared that their financial injuries do not stem from the actions of
the Defendant, but are instead the direct result of the Government's disruptive civil
takings and illegal possessory seizures.
2) The prosecution's alleged "fraud proceeds" are actually the legitimate funds of the
G-series investors -The prosecution's unilateral characterization of the G-Series
investments as 'fraud proceeds' (Doc 716-4) represents an impermissible
expansion of federal forfeiture authority. Under established Second Circuit
precedent, the Government cannot simply declare an entire pool of legitimate third
party capital to be the fruit of a criminal enterprise. Petitioner maintains that this
classification is legally untenable and structurally invalid under 21 U.S.C. § 853(n).
Page 2of 5

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 4 of 61
3) The Government's asset seizure rests entirely upon a legally unproven and
uncontested 'alter ego' theory that bypassed the mandatory requirements of a
formal evldentiary adjudication -The Chapter 11 Bankruptcy Trustee, Luc
Despins, summarily applied an 'alter ego' designation to the entire complex of G
Series investment vehicles without ever satisfying the strict evidentiary burdens or
securing the formal adjudication required by law. Compounding this error, the
prosecution adopted the Trustee Luc's unadjudicated alter ego theory within the
context of this criminal proceeding. This unauthorized coordination effectively
allowed the Trustee and the Government to rob Petitioner's~
legitimate life savings, achieving a permanent deprivation of third-party property
rights completely unmoored from standard procedural due process. Because this
asset seizure rests entirely upon an un-litigated alter ego assumption rather than
concrete, individualized tracing, the retention of these funds violates fundamental
tenets of federal forfeiture and bankruptcy law.
4) The prosecution systematically insulated the Defendant's alleged co-conspirators
from liability, offering immunity in exchange for testimony targeting the Defendant -
The anomalous procedural history of this case underscores a manifest injustice that
undermines the integrity of the judicial process. The prosecutors obtained a
conviction by immunizing the very individuals who currently possess in excess of
$100 million of un-seized investor capital (Doc 834), while simultaneously seeking
to block innocent third-party investors from asserting ancillary claims under 21
U.S.C. § 853(n). This unusual enforcement posture, shielding possessory, non
indicted actors while systematically denying a forum to innocent claimants calls
into question the structural legitimacy of the prosecution's framework and
highlights a systemic failure to safeguard the true victims of the underlying
enterprise.
5) An unadjudicated conflict of law wherein the subject asset pool is burdened by
two mutually exclusive designations (Case No. 26-361 )-The District Court has left a
critical threshold issue entirely unaddressed, permitting a 'dual-definition' paradox
to persist over the same asset pool. While the Communist PRC government
categorizes the G-Series capital as an illegal political fund targeting state security,
the prosecution had summarily branded it as 'fraud proceeds.' Byfailingto hold an
ancillary proceeding to adjudicate this geopolitical and legal conflict, the District
Court has abdicated its duty to determine the true legal status of Petitioner's
~ nl ife savings.

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 5 of 61
6) Witness duress & evidence tainting -An ancillary proceeding should be conducted
to address a major structural defect in the prosecution's case: the systemic tainting
of witness evidence via foreign state interference. The unauthorized transmission of
investor records to the CCP by Phoenix Farm CEO Wei Li hong initiated a wave of
political persecution against domestic investors. Under established due process
principles, a conviction or forfeiture cannot rest upon the testimony of individuals
inside mainland China who may have been coerced under threat of state violence to
falsely characterize their G-Series investments as fraud. Petitioner is entitled to an
evidentiary hearing to probe this pervasive witness duress and to ascertain the true
regulatory allegiance of the immunized farm leaderships.
REASON WHY THE WRIT SHOULD ISSUE
The All-Writs Act empowers this Court to issue a writ of mandamus directing the District
Court to docket all relevant documents to all parties, including 3,d party Pro Se petitioners
under 21 U.S.C. § 853(n). This Court should issue a writ of mandamus because Petitioner
has a clear and indisputable right to the writ. No other alternative remedies are available to
Petitioner. Mandamus is the only avenue by which Petitioners can obtain relief.
CONCLUSION
For the foregoing reasons, Petitioner respectfully requests that this Court issue a Writ of
Mandamus directing the District Court to:
1. Immediately file and enter Petitioner's Motion onto the official docket;
2. Authorize and issue subpoenas for the appearance and testimony of relevant, vital
personnel; and
3. Convene a formal ancillary evidentiary hearing as explicitly mandated by 21 U.S.C. §
853(n) to adjudicate Petitioner's cognizable legal interest in the ~ f
seized G-Series investment capital.
Petitioner further requests that this Court review the extraordinary procedural irregularities,
exercise its supervisory authority to correct a clear abuse of discretion by the District
Court, and safeguard the systemic integrity of the federal judicial process by restoring
Petitioner's fundamental right to procedural due process.
PRIVACY
Petitioner respectfully requests to file this petition in redacted public form with personal &
financial data redacted. A redacted set of the documents is provided.
'

Date: June 9", 2026

A-
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 6 of 61
1 Case 1:23-cr-00118-AT

3 UNITED STATES DISTRICT COURT
4 FOR THE SOUTHERN DISTRICT ~O~F__!:!N~E~W_.,.,.,.u.... _____

6 UNITED STATES OF AMERICA, Motion to Subpoena Luc Despins and
Key Himalaya Alliance & Farm
7 Plaintiff, Personnel; Evidentiary Hearing, &
Asserting 853{n} Rights, Privacy and
8 Declaration, By~ (Anna).

v.

11 HO WAN KWOK (A/K/A MILES GUO, MILES
12 KWOK, WENGUI GUO AND BROTHER SEVEN),

Yvette Wang,

Defendants.

Facts
17 My name is Anna, a G-series investor, appearing prose to tell the Court my
personal experience and facts surrounding my investments relevant to this

case.

1) My background - I am a retired.- a mother, and a Christian who
20 lives in communist China all my life. I have watched the CCP falsify
the Bible, ban its sale, and demand that the Chinese people worship the

Communist Party. They tell us that while our parents are dear, the CCP

must be 1dearest of all.' Having lived through this spiritual and
23 intellectual suppression, I am committed to speaking the truth about
the regime1s attempt to replace God with the Communist Party.

2) The taking down the CCP movement - My involvement in the taking down

the CCP movement is rooted in my lifelong experience as a victim of
26 state-sponsored religious and political persecution. Since 2017, I have
been a supporter of Mr. Guo, viewing his movement as a necessary

vehicle for exposing the CCP's human rights abuses. On June 4, 2020, I

participated in the establishment of the New Federal State of China, an

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 7 of 61
1 organization dedicated to the peaceful transition of China toward a
democratic, CCP-free future.

I categorically reject the DOJ prosecutors1 characterization of this

organization as a 1cult. 1 Such labels are not only inflammatory but are
4 factually untethered from the reality of the CCP's documented
atrocities, such as forced live organ harvesting on the Chinese

children. I assert my First Amendment rights to freedom of association

and religious expression, maintaining that my support for Mr. Guo is a
7 matter of profound personal and spiritual conviction. To dismiss
thousands of global investors and activists as 'cult members', the

Government is to ignore the legitimate grievances of a population

seeking liberation from a totalitarian regime.
10 3) My investment in G-series -The investments I made were part of a
structured, global effort to support a free China. Mr. Guo designed and

promoted an ecosystem of independent entities: GTV(VOG), Himalya

Alliance, Himalaya Farms, G-Club, G-Fashion, Himalaya Exchange, and
13 Himalaya Reserve. Each entity was legally established under its own
jurisdiction and managed by its own operational team. My commitment to

support free China this cause was tangible: over a nearly three-year

period from May 2020 to February 2023, I executed 15 separate wire
16 transfers totaling$ from my hard-earned savings, Using
legitimate banking channels and necessary intermediaries, I directed

these funds to entities such as VOG, Korean En-Dian Farm, New Zealand

Farm, G-Club, and Himalaya Exchange. I also donated to the Rule of Law
19 Foundation. Those capitals were investments in a movement and in
corporate structures that I believed in; it was never an 'unlawful

proceed1 for the Defendant to exploit or comingled personal funds of

the Defendant,

Challenge to the Government's Unlawful Actions Against My G-series Investment

1) Communist China's transnational Financial Censorship on the G-series

investors - The pain, anxiety, and suffering I have endured because of
25 my choice to invest in the G-Series is a direct result of the CCP's
totalitarian grip on global finance. The Chinese Government

criminalized any investment into the G-Series. I knew with absolute

certainty that if I disclosed the true purpose of my wire transfers to
28 the banks, the transactions would be terminated immediately and I would

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 8 of 61
1 face severe state repercussions, This hostile environment forced me to
rely on alternative pathways to secure my investments.

3 In one heartbreaking instance, in 2021, I asked a friend
4 surnamed ... to use his business account to route approximately ......
USO for me through his to ... Because

of this single act of assistance, the bank froze his entire corporate

account for the reasons of "money laundering" and "threatening national
7 security". He fought this injustice fiercely, pursuing both a lawsuit
and an appeal, but he lost both. The Chinese Government fined him and

threatened to jail him too. Witnessing the financial ruin of a friend

who simply tried to help me escape financial censorship has caused me
10 immense psychological trauma. My use of intermediaries was never an
attempt to mislead any financial institutions; it was the only viable

survival mechanism available to an. oppressed citizen trying to move my

capital to freedom.

In the context of Second Circuit Case No. 26-361, Tony's grievance

reveals a profound flaw in the DOJ. prosecutors' narrative. The District

Court has yet to answer a vital question: How can the identical pool of
16 money be treated by the PRC authorities as an illegal, 'anti-Chinese
government' fund that threatens national security, while the U.S.

Government insists it is nothing more than 1fraud proceeds1?

This dual classification is a logical impossibility. If the money was
19 deployed by independent citizens as a financial shield against an
oppressive regime resulting in domestic freeze orders and police

interrogations in China, it represents legitimate, hard-earned capital

risked for freedom. The Government cannot adopt the asset-pool
22 dimensions manufactured by the CCP's financial blockade without
implicitly validating that regime1s suppression of its own citizens,

By failing to address this contradiction, the record remains silent on
25 a critical distinction. The funds injected into the G-Series by
independent investors were sent with clear, anti-totalitarian political

intent. To treat these politically motivated capital contributions as a

standard, unified fraud scheme is to ignore the documented reality that
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 9 of 61
1 these assets are viewed by a foreign adversary as weaponized dissent,
not criminal booty.

2) The DOJ's reliance on the affidavit of FBI Special Agent AnthonY Alecci
4 (SONY Doc. 716-4) is legally insufficient to justify the sweeping
•
forfeiture of G-Series assets. Agent Alecci cites 18 U.S.C. § 981 and§

1956 to characterize these funds as 'proceeds1 of wire and bank fraud.

However, this characterization fails as a matter of law.
7 My capital contributions were made with bona fide intent and originated
from legitimate, post-tax earnings. Under the Second Circuit's 'merger

doctrine, 1 the Government cannot classify the mere movement of funds

between accounts as 'money laundering' unless it first proves those
10 funds were already the proceeds of a completed crime. Here, the
Government has failed to establish a nexus between the alleged fraud

and my specific assets. Furthermore, the Government's theory of fraud

is contradicted by the 1victims1 themselves; as noted in Document 834,
13 the vast majority of investors expressly reject the Government's claim
that they were defrauded, asserting instead their status as lawful

property owners under§ 853(n}.

16 Agent Alecci's investigation (SDNY Doc. 716-4) relies on a logical
fallacy: that the frequency of transactions automatically equates to

the concealment of proceeds under 18 U.S.C, § 1956(a) (1) (B) (ii. In

reality, my investments were never 'fraud proceeds' to begin with. They
19 were legitimate investmentS intended for the G-Series ecosystem,
Forfeiture requires the Government to prove a criminal 1taint1 by a

preponderance of the evidence. Forfeit assets before adjudication

before thousands of investors who overwhelmingly disclaim 'victim1
22 status {SONY Doc 843), the Government has committed a civil taking
without the required proof of a crime. Moving money between legally

formed entities is a standard business practice, not a specified

unlawful activity under 18 U.S.C. §§ 1343 or 1344.

The Government's Victim Identification and Classification Crisis

From the standpoint of a G-series investor who rejects victim status, who

refuses to proceed under the CVRA, and instead seeks recognition of
28 independent third-party property interests under 21 U.S.C. § 853(n), the

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 10 of 61
1 Government's current victim framework is not merely inconsistent; it is
structurally unsound and procedurally dangerous.

1) Selective Gatekeeping of Victim Status

In SONY Doc 511, the Government adopted an extraordinarily broad
4 definition of the purported victim population. It stated that "one group
recognizes the fraud for what it is and believes the defendants

deliberately deceived them," while "the other group does not believe they

were defrauded (either because they are complicit in the conspiracy, or
7 they have been misled by it). Many now believe the government wrongfully
seized their money." Under that formulation, the Government's victim

theory is broad enough to sweep in not only self-identified victims, but

also investors who reject the label of victim and believe the Government
10 has wrongfully taken their funds. Yet when those same or similarly
situated investors appear in court in a procedurally adverse posture, the

Government's framework shifts. After the district court adjourned

sentencing from April 27, 2026 to June 29, 2026, the Government filed
13 oppositions to 4 of the Emergency Stay Applications at the Second Circuit:
Ryan Bai (No. 25-2726), Tony (No. 26-361), Chunk Chyi (No. 26-77), and

Carolyn Sun (No. 26-441). As reflected in Chunk Chyi's response filing in

Second Circuit No. 26-77 (0kt. 18), even after he affirmatively invoked
16 the CVRA and identified concrete financial loss, the Government
nevertheless sought to characterize him as a mere "supporter,u rather than

as a victim entitled to meaningful consideration. Chunk correctly

identified the resulting distortion: victim recognition appears to
19 function less as an equally available statutory protection and more as an
advantage effectively reserved to those with representation, procedural

leverage, or institutional acceptance. This disparity is particularly

stark, as noted on Pages 3-4 of the filing, where Chunk observed that
22 certain represented HEX claimants reportedly deny being "victims," but the
Government treats them as "victims" in sentencing the Defendant. By

contrast, Pro Se petitioners who affirmatively assert loss and invoke the

CVRA are met with arguments by the Government that their victim status is
25 insufficient or that their losses should not be counted. The inconsistency
becomes even more pronounced in light of the record cited on Page 8.

There, Chunk references the defense counsel's submission in SONY Document

843, reporting that counsel had received 1,254 "supporter statements.11
28 Under the Government1s own formulation in Document 511, such individuals

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 11 of 61
1 would appear to fall within the category of persons who do not believe
they were defrauded yet whose funds are nevertheless counted within the

broader victim framework. Yet, rather than being treated as victims by the

Government, these individuals were effectively represented through defense
4 counsel.

Taken together, the records support a troubling inference: in practice,

the Government's recognition of "victim" status appears to operate in a
7 manner that privileges sophisticated representation. Those with counsel,
institutional alignment, or procedural leverage may have their positions

incorporated into the Government's sentencing narrative, but for the Pro

Se individuals, the Government labels them whatever the Government sees
10 fit, sometimes totally against those Pro Se individuals' will. This is not
a neutral application of a statutory framework. It is a structurally

selective system that conditions access to victim status, and the rights

flowing from it, on litigation posture rather than legal entitlement.

2) Selective Gatekeeping of Exit from Victim Status

The contradiction becomes even more revealing in the Government's

opposition to the Emergency Stay Applications filed by the 4 Pro Se
16 petitioners in the Second Circuit. There, despite the breadth of its own
Document 511 definition, the Government effectively treated those 4

petitioners as supporters of Mr. Guo rather than as persons falling within

the broader victim framework it had previously asserted. I myself reject
19 victim status, refuse to proceed under the CVRA, and identify instead as a
G-series investor and supporter of Mr. Guo. From that standpoint, the

Government's treatment of those· 4 Pro Se petitioners as "supporters" is a

deeply troubling. It suggests that the only practical way to escape the
22 Government's default victim classification and to assert an independent
position is to confront the Government directly in court, and to do so

with unusual procedural sophistication and persistence.

25 That is a profound defect in the Government's framework. If only a tiny
number of exceptionally capable litigants, such as Ryan, Chunk, Tony,

Carolyn and similarly situated petitioners can force the Government to

stop treating them as passive "victims" and instead acknowledge them as
28 procedurally independent actors, then the Government's classification

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 12 of 61
1 system is not functioning as a neutral legal framework at all. It is
functioning as a selective gatekeeping device. In practice, it leaves

ordinary G-series investors trapped inside a broad victim label when that

label benefits the Government's loss and sentencing narrative, yet denies
4 them any realistic path to independent recognition unless they possess
extraordinary litigation ability. That is not a stable victim framework.

It is a procedurally distorted structure that risks depriving ordinary
6 investors of due process, meaningful access to§ 853(n), and equal
7 treatment under the law.

What the record reflects is not merely inconsistency of the Government's

conduct, but the absence of a stable and administrable rule governing
10 victim classification. A framework that expands to include certain
individuals as "victims" to support the Government's loss attribution, yet

contracts to exclude those same individuals when they attempt to assert

independent procedural rights. It proves that the Government operates
13 without a discernible limiting principle. In practice and in reality, it
forecloses any predictable or accessible pathway for similarly situated

investors to assert their rights under 21 U.S.C. § 853(n), and thereby

raises serious concerns not only of fairness, but of the framework's legal
16 viability.

Constructive Fraud on the Courts: The Manufacture of an Utterly Fictitious

"Alter Ego" Pool and the Poisoning of the Trial Record
19 The DOJ prosecutors and Chapter 11 Trustee Luc Despins have engaged in a
pattern of material omissions that amounts to a constructive fraud on the

courts. By systematically withholding the fact that a substantial portion of

the seized funds comprised untainted, legitimate capital from independent
22 investors and asserting instead the absolute falsehood that 100% of the
corporate assets were "criminal proceeds11 the Government and Trustee Luc
23 ,
engineered a procedurally deficient record to serve a predetermined

narrative.
25 This orchestrated omission produced three devastating legal consequences:
1) The Artificial Manufacturing of the "Alter Ego11 Pool

The Trustee and the Government bypassed mandatory tracing requirements to

fabricate a sweeping, all-inclusive "alter ego" theory. By failing to
28 disclose the presence of$ in bona fide capital from me and

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 13 of 61
1 hundreds of millions from similarly situated investors, the Government and
Trustee Luc induced the bankruptcy court and the District Court to enter an

overly broad forfeiture pool. They effectively transformed distinct corporate

entities with separate fiduciary duties into a monolith, seizing innocent
4 third-party property under the guise of recovering criminal proceeds.
2) Structural Deprivation of Procedural Due Process

By presenting an artificially clean narrative of total corporate fraud, the

Government and Trustee Luc effectively suppressed the statutory rights of
7 third parties under 21 U.S.C. § 853(n) before the trial even began. They
presented the District Court with a curated, unchallenged record, ensuring

that any subsequent ancillary proceeding would be treated as an

administrative afterthought rather than a mandatory, adversarial adjudication
10 of superior legal title.
3) The Contamination and Pollution of the Jury's Fact-Finding Mandate

This mischaracterization extended directly into the criminal trial,

fundamentally infecting the trial record. By introducing high-volume bank
13 accounts as unified 11fraud accounts" while deliberately concealing the
massive infusions of untainted investor capital, the Government presented a

distorted financial landscape. This material distortion polluted the minds of

the jury, creating an illusion of total criminality that stripped the
16 Defendant of a fair trial and starved the jury of the context required to
accurately evaluate criminal intent.

A court-appointed Trustee and federal prosecutors owe an absolute duty of
19 candor to the judiciary. When they actively ignore the distinct, clean origin
of investor funds to artificially inflate a forfeiture pool, they do not

merely commit an error; they perpetrate a constructive fraud that undermines

the integrity of the entire judicial system. This Court must intervene to
22 halt the finalization of this manufactured record.

Motion to Subpoena and to Conduct Evidentiary Hearing on Luc Despina of Paul
25 Hastings LLP and Key Himalaya Alliance and Farms Leadership Personnel
I respectfully move this Court for an Order issuing subpoenas to Luc Despins

(Chapter 11 Trustee, Paul Hastings LLP), and key leadership personnel of the

Himalaya Alliance and Farms, including Wei Lihong, Zhang Yongbing, Ha-En,
28 Cosmos, Guo Shuai, Xia Qidong, William Je and Wang Xuebing. I further request

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 14 of 61
1 an evidentiary hearing to investigate the potential compromise of investor
data and the resulting transnational repression faced by the G-series

investors.

4 1) Wei Lihong (aka Sarah Wei, MIM~), formerly Arizona Phoenix Farm CEO,
in charge of the VOG investment.

Basis for her Subpoena: I assert that Wei Lihong acted as a fiduciary

for my investment of$ USD wired to VOG/GTV in . This
~
7 investment required the disclosure of my highly sensitive personal
identifiable information (PII).

a) Evidence of compromise and transnational repression:

State interrogation - Following the transfer of funds and PII to Wei
10 Lihong, I was subjected to three separate interrogations by the
Ministry of State Security (MSS) of the People's Republic of China

(PRC) and local police,

b) Unauthorized disclosure of my data: During these sessions, PRC
13 officials explicitly stated that my denial of investment was futile
because Wei Lihong had provided a list of "anti-government" GTV/VOG

investors and my name was on it.

c) Ongoing Harassment: As a direct result of this betrayal, I remain
16 under state surveillance, facing restricted movement and reporting
to local police during travel.

A subpoena is required to determine:

• Whether investors who were betrayed by Wei were systematically coerced

by the CCP into falsely reporting to the FBI that they were "defrauded"
20 by the Defendant.
• Whether the written victim statements currently relied upon by the

Department of Justice {Doc. 833) to calculate sentencing and forfeiture

guidelines were procured under extreme duress by a foreign totalitarian
23 regime seeking to sabotage the G-Series ecosystem
A subpoena compelling the testimony of Wei is critical to safeguarding the

integrity of these judicial proceedings. Wei's testimony is strictly

necessary to uncover a severe breach of investor data that directly impacts
26 the credibility of the Government's criminal case and the forfeiture pool.
Another question is whether Wei is a CCP agent at the beginning but disguised

as an anti-CCP fighter? How many of the Himalaya Alliance and Farm key

leaders are CCP agents under cover?

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 15 of 61
1 A critical issue impacting the integrity of these proceedings is the
potential role of covert foreign actors operating under the direction of the

People's Republic of China (PRC). An evidentiary hearing is necessary to

investigate whether key figures within the G-Series leadership specifically
4 Wei and other prominent leaders within the Himalaya Alliance and Farm acted
as unregistered agents of a foreign power, in violation of 18 U.S.C. § 951

and the Foreign Agents Registration Act (FARA), 22 U.S,C, § 611 et seq,

7 It is a matter of record before U.S. federal courts and intelligence agencies
that the Chinese Communist Party routinely utilizes 11controlled opposition"

and deep-cover operators to infiltrate overseas dissident groups, capture

proprietary data, and manipulate domestic legal processes. The sudden,
10 unauthorized data breach of the corporate 11investor list" to PRC security
organs raises a profound question of law and fact: Did Sarah Wei operate from

the inception of these programs as a disguised asset of the PRC state

apparatus designed to sabotage the movement from within?

The potential exposure of multiple undercover CCP operatives within the

leadership structure of the Himalaya Alliance directly threatens the validity

of the underlying criminal and forfeiture record. If key organizational
16 figures were hidden foreign state assets, their cooperation agreements with
the Department of Justice, their management of corporate assets, and their

interactions with the FBI cannot be deemed reliable.

Their operational objective would be perfectly aligned with the geopolitical
19 goals of the PRC: to engineer a collapse of the G-Series ecosystem, secure
the freezing and forfeiture of dissident capital, and manipulate U.S.

judicial resources to finalize an international financial blockade against

political opponents.

The Court cannot permit a forfeiture pool to be finalized when there remains

a substantial, unexamined risk that the corporate leadership who controlled

the underlying funds were covertly executing the directives of a hostile
25 foreign government. Discovery and cross-examination are strictly required to
unmask the true affiliations of those key actors and protect the integrity of

the United States judiciary from foreign state subversion.

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 16 of 61

2) Luc Despins of Paul Hastings LLP, Chapter 11 Trustee for the Estate of
2 Ho Wan Kwok (Mr. Guo)
Basis for Subpoena: As the court-appointed Trustee, Luc Despins has gained

control over vast amounts of G-series investors' investment including my

ollars wired to G-Club. Trustee Luc has a fiduciary duty to the
5 Court to accurately report the nature of the estate's assets. However, the
designation of my G-Club fund as the Defendant's personal property is a

material misrepresentation of the corporate reality:

a) Absence of Factual Nexus: I made bona fide capital contribution of

to G-Club, a legally incorporated entity with its own distinct
9 operational parameters.
10 b) The "Alter Ego" Misdirection: Trustee Luc maintained that G-Club was
merely an "alter ego" of the Defendant to justify his swallowing third

party capital into the bankruptcy pool. This sweeping conclusion was

presented to the bankruptcy court and to the criminal court without an
13 individualized tracing analysis of my legitimate funds.
14 c) Constructive Fraud on the Court: By failing to disclose to the Court
that a substantial portion of the seized funds consisted of untainted,

legitimate capital from independent investors and by claiming instead

that 100% of the assets were "criminal proceeds11, Trustee Luc and the
17 DOJ prosecutors have engineered a procedurally deficient record, and
manufactured Mr. Guo's alter ego asset pool for forfeiture, and

polluted the mind of juries in the criminal case.

Trustee Luc has cost the estate millions of dollars in administrative fees,

yet he has failed to provide a transparent, line-item accounting that
21 distinguishes between the Defendant's personal assets and my investment.
22 Proceeding to a final order without allowing me to cross-examine Trustee Luc
regarding the tracking of my ---investment violates basic tenets of

procedural due process.

3) Zhang Yongbing (~~9'), an immigration attorney of Illinoi, who was

retained to represent my interest regarding the return of my$
26 VOG investment. He was designated by the Government as the Defendant's
"co-conspirator" (Document 388). After the Defendant's arrest, Zhang

appeared on many of the Himalaya Alliance live broadcasts. Allegedly,
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 17 of 61
1 attorney Zhang represents numerous Chinese political asylum seekers who
also invested in the G-series, Allegedly, Zhang played a key role in

screening witnesses for Mr. Guo's legal defense and allegedly, Zhang

prevented some key witnesses who could exonerated Mr. Guo to testify on
4 Mr. Guo's behalf, claimant like Tony in Second Circuit Case #26-361,
allegedly,

Reason for subpoena: A material discrepancy exists regarding the return and
7 custody of my VOG asset. It is a matter of record that numerous similarly
situated investors who filed independent claims have already successfully

recovered their capital. However, my fund remains unreturned and unaccounted

for. A subpoena is necessary to compel a formal accounting from counsel to
10 determine the current legal status, location, and custody of my
asset.

I respectfully direct this Court's attention to an egregious procedural and

constitutional defect that invalidates the integrity of the underlying trial
13 record. As set forth in Document 388, Attorney Zhang Yongbing was explicitly
designated by prosecutors as an unindicted co-conspirator of the Defendant.

Despite this formal designation, the Department of Justice failed to prevent

this exact "co-conspirator" from participating in and screening the
16 Defendant's potential legal defense witnesses.
This alarming contradiction introduces two fatal legal errors into the

record:

a) Structural Infiltration of the Defense Camp and Incurable Conflict of
19 Interest
Under the Sixth Amendment, a criminal defendant is entitled to

conflict-free counsel and a private, uncompromised defense strategy. By

allowing an individual whom the Government officially considers a
22 criminal co-conspirator {Attorney Zhang) to act as a gatekeeper for the
Defendant's trial witnesses, the defense camp was structurally

infiltrated.

Zhang possessed an absolute, irreconcilable conflict of interest: as a
25 named co-conspirator seeking to avoid his own indictment, his primary
incentive was to protect himself and cooperate with the prosecution's

narrative-not to assist in developing a robust defense or locating

untainted investor capital.
28 b) Prosecutorial Exploitation of Witness Screening

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 18 of 61
1 The Government cannot have it both ways. Prosecutors cannot brand an
attorney as a criminal co-conspirator in official court filings to

destroy their credibility, while simultaneously allowing that attorney

to control, vet, and filter the witnesses available to the defense.
4 This arrangement effectively gave the prosecution a proxy inside the
defense infrastructure, allowing an insulated co-conspirator to

suppress or discourage critical testimony from independent investors

who could have proven that the G-Series funds were legitimate and
7 untainted.

The deployment of an unindicted co-conspirator to oversee or influence

the screening of defense witnesses represents a profound subversion of
10 the adversarial process. It suggests an orchestrated effort to control
the narrative, sanitize the trial record, and deny the Defendant a fair

trial. A full evidentiary inquiry into the scope of Attorney Zhang1s

interference with the defense witness pool is necessary.

41 Ha-En <~*JI<:!/') and Cosmos(~~~), both were former Korean En-Dian Farm

CEOs; William Je of ACA Capital; Xia Qidong (aka Longisland brother,

Changdao, ][;ltJR), former Himalaya Alliance Chairman, Mountain Spice Farm

CEO; Guo Shuai ($ililji • 1,l:;l,1VJ,'llf, Chaogen Xiaoge), Himalaya Alliance leader

I
19 On 2020, I wired $ dollars to the Korean En-Dian Farm Loan
Program. Ha-En said that CEO Cosmos who was sent by the Himalaya Alliance

took the money. But on ~2022, Guo Suai (Chaogen Xiaoge), an Alliance

leader made a public announcement alleging that team Cosmos had committed
22 fraud and he was suing team Cosmos.

Reason for subpoena:

a) In Government Document 273, the DOJ prosecutors asserted that ACA Capital
25 received $130 million in Farm Loan capital. ACA Capital is a distinct
corporate entity with no legal, financial, or familial ties to the Defendant,

the Defendant's family, or his family trust.

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 19 of 61
1 b) In Document 804, the Defendant stated that a number of independent
Himalaya Alliance CEOs and others hold custody and possession of

approximately $100 million in capital including the Farm Loan fund.

4 A subpoena is required to compel these individuals to testify under oath and
produce financial records clarifying the true custody and ownership of the

Farm Loan assets. I seek to expose a fundamental flaw in the prosecution's

logic:

• The Tracing Failure: If $130 million of the Farm Loan capital is held

by ACA Capital and or separate executives {Himalaya Alliance CEOs) and
9 or others, the Government cannot meet its statutory burden to prove
that these funds represent the Defendant's criminal proceed.

11 • The Manufactured "RICO Enterprise": By blindly pinning the independent
financial actions of ACA Capital and the Alliance CEOs onto the

Defendant, the DOJ prosecutors have manufactured a fictitious RICO

asset pool. They have converted independent, third-party corporate
14 capital including my own contributions into a centralized "criminal
enterprise" without performing the mandatory line-item tracing required

by Second Circuit case United States v. Banco Cafetero Panama, 797 F.2d

1154 (2d Cir. 1986).

The Court cannot allow the Government to seize an entire corporate ecosystem
18 under a RICO forfeiture order when the record proves the Defendant lacked
ownership and control over $100 million dollars of the funds in question.

Subpoenas must be issued to ACA Capital and the Himalaya Alliance leadership

to compel a transparent accounting and halt this unconstitutional inflation
21 of the forfeiture pool.

23 5) Wang Xuebing (or Wang Xuebin, 3'.<g/Jjq, CEO of the New Zealand Farm and
Himalaya Alliance Chairman

The testimony of Wang Xuebing is vital to resolving a core dispute of fact in

this forfeiture proceeding: whether the G-Series Farm Loan funds were the
26 "alter ego" of the Defendant or whether they were entirely controlled,
manipulated, and withheld by independent regional operators.

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 20 of 61
1 My specific transactional history provides prima facie evidence of
independent third-party management and potential self-dealing:

a) The Capital Contributions: Between 2020, and

2022, I executed a series of wire transfers totaling

directly to the New Zealand Farm Loan program.

b) Procedural Irregularities: At the direction of Mr. Wang's direct

subordinate {Wen Xiao), I was instructed to execute a blank Farm Loan
7 contract, specifically was told to omit the date and the dollar amount,
leaving only my signature (attached hereto as Exhibit). This highly

irregular procedure ensured the contract was never properly executed or

counter-signed by Wang Xuebing, leaving my fund entirely exposed.

c) Post-Arrest Unilateral Modification: The Defendant was arrested on
11 March 15, 2023. Months later, ontll■■■■, 2023, while the Defendant
was in federal custody and completely unable to attend any corporate

entities events, Wang Xuebing executed a unilateral contract extension

(attached hereto as Exhibit), arbitrarily extending the Farm Loan
14 maturity term by an additional two years without my consent or
knowledge.

16 The Government's forfeiture case relies on the theory that the Defendant
maintained unfettered dominion and control over all incoming investors'

funds. Mr. Wang's actions completely refute this:

• Independent Dominion: The fact that Wang Xuebing could unilaterally

alter financial contracts and retain of my capital after
20 the Defendant1s arrest conclusively proves that the Defendant did not
possess or control these funds.

22 • Investigating Potential Conversion: I have a right under Fed. R. Crim.
P. 32.2(c) to discover the current location and custody of my asset.

Mr. Wang1s deceptive practices strongly indicate an intent by local

leadership to convert the Farm Loan program capital to their own
25 personal use, entirely independent of any alleged conspiracy by the
Defendant.

The Government cannot legally forfeit my as property of the

Defendant when an independent operator in New Zealand is actively altering
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 21 of 61
1 contracts and withholding the funds. A subpoena is strictly necessary to
compel Wang Xuebing to account for the precise location of my capital and to

expose the fatal defects in the Government's "alter ego" forfeiture

narrative.

5 In conclusion, the current evidentiary record in this case is fundamentally
flawed because it relies on the unvetted narratives of individuals who have a

profound financial and legal interest in concealing the truth. As established

in Document 388, individuals such as William Je, Xia Qidong, Wei Lihong
8 (Sarah Wei), and Attorney Zhang Yongbing are designated co-conspirators of
the Defendant.

10 Upon information and belief, Xia, Wei, and Zhang have entered into non
prosecution, cooperation, or immunity agreements with the DOJ. In exchange

for accusing the Defendant of wrongdoing and su~porting the Government1s

narrative, these individuals have been insulated from indictment.

The structural defect in the Government's forfeiture and criminal narrative
14 rests on three critical realities:
15 a) The Insulated Parties are the True Custodians of the Assets

While the Government ha~ systematically pinned 100% of the financial
17 liability on the Defendant under an overbroad "alter ego" theory, the
documentary evidence demonstrates that it is these unindicted co-conspirators

who exercised autonomous control over, and actively withheld my capital,

including the$- VOG investment handled by Sarah .Wei and later by Zhang
20 Yongbing.
21 b) Weaponized Coercion and Witness Bias

By granting immunity to the very operational leaders who managed the day-to
23 day transactions of the G-Series entities, the Government has incentivized
these actors to mischaracterize legitimate third-party capital contributions

as "fraud proceeds, 11 This arrangement allowed these co-conspirators to

deflect criminal culpability while simultaneously shielding themselves from
26 accounting for the missing investor funds.
27 c) The Absolute Necessity for a Rule 32.2(c) Ancillary Hearing
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 22 of 61
1 My right to due process cannot be bypassed by an administrative agreement
between prosecutors and self-interested co-conspirators. To determine the

true "taint11 and ultimate disposition of the seized property, these

individuals must be formally summoned to court. I have a statutory right to
4 subject these witnesses to rigorous cross-examination at a mandatory
evidentiary hearing to uncover the location of her missing property and

expose the manufactured nature of the forfeiture pool.

For the foregoing reasons, I respectfully request this Court to vacate the

premature forfeiture determinations and remand this matter with instructions

to issue the requested subpoenas and immediately convene a full ancillary
10 proceeding.

12 Preyor For Relief

WHEREFORE, I respectfully request that this Court enter an Order granting the
14 following relief:
1. Recognition of Statutory Title: Formally recognize my standing and

property rights as a superior·, bona fide owner under 21 U.S. C. § 853 (n)

regarding all documented capital contributions made to the G-Series
17 entities;
2. Issuance of Subpoenas: Issue subpoenas ad testificandum and duces tecum

pursuant to Federal Rule of Civil Procedure 45, compelling the

appearance and production of records from the following material
20 witnesses:
o Luc Despins, Chapter 11 Trustee (Paul Hastings LLP)

o Wei Lihong (Sarah Wei), former CEO of Arizona Phoenix Farm

o Attorney Zhang Yongbing, legal representative for investor claims
23 o Wang Xuebing, CEO of the New Zealand
o Guo Shuai, Ha-En, and Cosmos leadership personnel

o William Je, ACA Capital;

3. Conduct Evidentiary Hearing: Convene a full ancillary evidentiary
26 hearing pursuant to Federal Rule of Criminal Procedure 32.2(c} to
accurately determine the true, traceable dimensions of the forfeiture

asset pool; and
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 23 of 61
1 4. Additional Equitable Relief: Grant such other and further relief as
this Court deems just, proper, and necessary to protect Petitioner's

procedural due process rights and prevent a constructive fraud upon the

Court.

Privacy/ Sealing Request Under Fed. R. Crim. P. 49.1

I respectfully request to file this motion in redacted public form (redacting

name, address, email, phone, financial data and sealing my ID information
7 such as name, address, DOB, ID# etc.).

Declaration

I declare under penalty of perjury that the foregoing is true and correct to
10 the best of my knowledge and belief.

Respectfully submitted,

Dated, May 21, 2026

Ann~

Certificate of Service
16 I certify on May 21, 2026, submitted this filing to:
The Court's Pro Se Intake for docketing

via email ProSe@nysd, uscourts. gov

and
19 via US Mail:
Clerk of Court

United States District Court

Southern District of New York
22 500 Pearl Street
New York, NY 10007

US Attorney's Office SONY:
25 • ryan.finkel@usdoj.gov (Ryan Finkel, Assistant US Attorney)
26 • justin.horton@usdoj.gov
• micah.fergenson@usdoj.gov

Defense counsel:

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 24 of 61
1 • msarafa@sarafalaw.com
2 • jdratel@dratellewis.com
• jkaley@doarlaw.com

Attachments/Exhibits: Personal ID, Investment Proofs and Evidences

Respectfully submitted,

Signature~
8 Print: Name Anna
Address:

Telephone:r:i,
.10
Email: _._

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 25 of 61
LIST OF THE ATTACHMENTS/EXHIBITS
1) MYID
2) SUMMARY OF MY INVESTMENT
3) PROOF OF MY INVESTMENT -19 PAGES
4) -FROZEN FRIEND BANK
5) AGREEMENT WITH ATTORNEY ZHANG YONG BING TO GEl ftj 1/OG REFUND
6) KOREA EN-DIAN FARM MATTERS
7) NEW ZEALAND FARM LOAN MATTERS

CCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 2266 ooff 6611
. . ... .. .. .
..
tT hh ee M Pi en oi ps lt er 'y
s
of
Re
F po ur be li oig ncn d, se o l f mf ia li C it h ts i an ra
y
foreign cornit
c # XE MI FI
-PEOPLE'S
REPUBLIC OF CHINA
CHŇ
EPASSPORT ..
PE / CHINESE
公安部出入境管理局
MP'S Bit & Entry Administration

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 27 of 61
-
,~
OATE !!_OM MY ~q)l)ff! TO ACCOUNT tl'WAOUGH JJW PAATY/MIOOl.E MA/I!) AMOUN< ~USO
=
~ AGFtlOJLTUAAl SAN( CF 0-!INA; S(L,f, ACCf, \l.t1:<LS~AI! - =
......jj ijiji>'l AGRlCULTUAAL !lAN)( OF 0,1NA, SE:U:, A; W'El~FARGO, -
TOTAi. VOG/R£P'IU.S£NT£0 eY ATTORNEY ZHANG YONGBING -
- STANOAAOO·iA$T(R$.<l.Nl(.s(lf,ACCT NONGl'!YUPSANJ(, - USO ,.oot,,(. . :-,,,. . , ....... ~
TOlAl TO KOREAN £N DIAN FAAM I.O.v! HA-EN/COSMOS - s
-
' s ......, O 0,i 1lN NA A C COO NN Ss 'In R! WU Ccr l"t IO ON N e 8A ,AN N.! lC (;. -S sf n.l. FF ;, A ACC CT Cii T9 .I -I - • " ,u" A" N' RRA A.T nT: ~@I Ll. 77 ,- .,;v,~ :i........• ..::,. . .. .. ... .. . . <. .: ¢;; .1., .. '1,i
' lii 1~ COJ\ISTRUC!10N f.,>,NK. s.flF; Al::CT ... '""" RA.TT: f! 1·7 --~.,~.,..,~,...,~,.,.
' :NA, CONSTRucr10N BANI(; SELF', ACCT~ YUAN RATE@l:7
a 11'<A.CONS'TiUJCTION BANIC;SE:lf;~. .. - ,UAN AAT'£ql:1 -~•--<OJ.N~~
• AGRICUtTlJAAI. 6ANKOJ OllNA;SEtl';ACCT-- ,UL, RATI:@ 1.:?. _l;l.........:,,...,wu:.,..•-.;,
,UAN s -
-
" _411_111 _1_11 !' 'O'IINA C.ONSTRUCTlON BAN.K,.S£U', ,UAN
ll 0-11"-A CONSTRV<TlON BA.Nltstlf;.ACCT ,UAN
,N CONVEl'ITTO T.- ,UAN «:,. ... -.==..,,i.=,
-
" ,,,,,,_. O'llNA CONSTRUC'. {J. Q l,18,AN' ,,.,,,o ""'" f,O,uO~.:,~)U
..,
" ....... .llGRlC..lTlJAALSANKOl'CHlN~_Sl:LF.~ ,UAN
" -._...._-. ~_JNACO_IIISTR VCTION BANl(;.Sf '""'
,UL, ~acma,o:==
TOTAi. TO GOJJB '""' $
" U'lB/2023 AGJ.llCVLTU~L 13AN(OF O!INA ""' -V5QT',. .- -:. ...
TOT~ TO H-001.1.AA,.hJSf:DTO BIJ'nt<QU,j_-':_l.10_~~ .!_UCM
GRANO TOTAL FOR All INVESTMENT

CCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 2288 ooff 6611
汇款详情
账 户
款
你子账户 美元肌汇
0.00美元(手续费)
0.00美元(电报费)
国际支出金额 小美元
汇款状态 受理成功
收款方名称
收款账户
SWIFT/BIC
收款银行名称 WELLS FARGO BANK, N.A

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 29 of 61
NAMIC
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 29 of 61
ULTURAL BANK OF CHINA
交易类型:汇出非款
受理终端:
发光案号
客户姓名气
交易结果:交易成功
出证金额
成交汇率
收款方姓名:THING RET
汇款金额:
汇头巾神:美元
费用承担方式:共同承担
于续费:
邮电费
附言:
受理日期/时间
行 股份 有
限
公

CCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 3300 ooff 6611
不易所需的短信验证码为
转入账户居民 收款,
产的金额 USD。切勿
将验证码告知他人!请警惕电信
作骗,切勿向陌生人转账汇款。
● EMUI已防止第三方应用服避读取和使用
上证码:超级游离世人,
自制验证码
尊敬的客户,您
本次海外电汇申请(序列号
已提交
处理。
2分钟
尊敬的客户,您
本次海外电汇交易(序列号
“已成
功。
2分钟前
的
您尾号

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 31 of 61
-
BH 1E K9aA
A
MN r c- &
c
T
om rC oeu
u
nrs
sn
t c oo tu cm ts Ne it or uo
n
m mN Pe ba er e
r
Mm r ia : oe i cl hing Address: 「 I人 ndi活 vid期 ual账 Ac户 cou交
nt
T易 ran明 sac细 tion D
交易白期
Posting Date Transaction Date 收 支 出 I入ncome/
Expense
Amount
Balance
Transaction
Name

利点
支
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 31 of 61
出
转账
END

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 32 of 61
YMA (TWEN)
将702, 721, 373韩币, 칠억이백칠십이만일천상백칠십상원
韩币交予联盟委托收款人:
1. 營團(溫暖姐姐)
2. 成先钠(西朝鮮)
3. 王環皓(至時时刻)
地点: 서울시 도림동216-2.
查验并交付完成
2021.04.05
委托人签字 付款人签字 收款人签字 사
1.성선 명
1.
2 张丽

3.主張皓
•
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 32 of 61

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 33 of 61
交易账户 建设银行
交易时间
交易地点/附言 跨行转出
对方账户
记账日
账户余额
tt:
,'"<'
J=Y
~;<)
J<)
~~<)
Jl(
*
m}8
m}8
m}8
tJ
1=>
}l
%
II=>
9}
lII
*
%
~
~
*
,-
}I
r-o~
}l
}A'l!
I.!!!.
1l=l
~. ~ ~HD
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 33 of 61

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 34 of 61
跨行转出
交易账户
交易时间
跨行转出
交易地点/附言
对方账户
记账日
一 -
,~,
r¢)
~<)
~~<)
.it:
J7(
~
~
~
tr::;
]:~
=
K,o
s
9}

~
]JI
~
~
}t
j!!!,
rG~
}I
~ ~ tllD
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 34 of 61

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 35 of 61
跨行转出
¥ 00
交易账户
交易时间
交易地点/附言 跨行转出
对方账户
记账日
账户余额
1::=:>
~<)
t¢>
t~<)
+J
.'( .', .': L'
uIJ,~,r,<
- '1
'
·,.r.,
D1)s
D1)s
tr::~
t:?:>
1l
~
-·~}:.'V "''"·
.$
M
J:S;
JD
>'*
~
,!':!
,-
}1'
rD~
}1'
});iJ
JEJ
IJ;::::>
'
~ rllD
•
0 0
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 35 of 61

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 36 of 61
跨行转出
交易账户
交易时间
交易地点/附言 跨行转出
对方账户
记账日
I
-1¢}
J<)
~)<)
.it::
IJ""\ Jl[
tJ2
~
~
~
=
3;
m
~
+:::L
~
,r:,r
rL
rD?
}1
~
~ !:s: ~ ~IID
- IJ
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 36 of 61

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 37 of 61
交易类型 向他行账户转站
交易渠道 手机银行
转账金额
大写金额
凭证号
收款方
户名
账号
收款银行
付款方
-
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 37 of 61
- -
-
户名 电子回单
专用章
账号

\/
,
h
.
~
~ ~J
'
~ ->
~ }I
..
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 38 of 61

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 39 of 61
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 39 of 61
务凭证
MÍMỘTVỊ

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 40 of 61
跨行转出
¥
交易账户 建设银行
交易时间
交易地点/附言
对方账户
记账日
...
'/(''
.
,.
:,
.
.. ,.-,,,.,•,
, ...
.,;,'
·'
..
. ,I
,I;<}
-I)<)
~)<)
it:
'
~
~
~
~
=
,·
..
~

~
~_,fP
JJI
}
,-
}I
J!!J
rD~
}I
"
~ ~1m
I ,
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 40 of 61

'
'
~ •
I
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 41 of 61

CCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnnttrryy:: 11..11,, PPaaggee 4422 ooff 6611
交易时间
交易类型 问他行账户转账
交易渠道
手机银行
转账金额
大写金额
凭证号
收款万
户名
账号
收款银行
付款方

CCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 4433 ooff 6611
通知收款人
付款人
收款人
收款账户
收款银行
交易时间

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 44 of 61
跨行转出
交易账户
交易时间
交易地点/附言
对方账户
记账日
r¢>
r¢)
~~<)
~
u''r"
t
t]
r"
ti:::
a
a
~
~
~
~
'
l:p
s
m
>t
.
~
,
-4
~
~
(
'
JBJ
rD~
rL
}~~ j,:
'
,'
)''•
~ tllll
J
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 44 of 61

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 45 of 61
1 一 2 す 1 一 一 -
付款人
付款账户
收款人
收款账户
收款银行
转账金额
-
- 一
川
红
色
_..._
..
•,,_I

. .~
· .
.•~
·~
.
:li/1
..
~i
~i
'
~·
·~
·~
~·
->
->
~
.~
.~,
......
~
'
}1
}1
II-'
~
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 45 of 61

CCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 4466 ooff 6611

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 47 of 61
THE
J上 UA海 NGU商 AI業 CO儲 MME蓄 RC銀 IA行
L
&國 SA際 VIN金 GS融 DA業 RK,務 LT分 D Q行 UU DRANCIL
CURRENT ACCOUNT WITHIDRAW SLIP AND APPLICATION FOR OUTWARD ELSINITAN
Date
ft It - 1/\Ve dechart that I/we am are not a local individual, corporate body of govemment In
nt ofitince and
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 47 of 61
E
S E
char
horized to debit miyfour AIC No.2710800 EX
B
a
n
k
'
s
C
o
p
y
會國士全小限度,段便會日自上門休产主で
一

CCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnntrtryy:: 11..11,, PPaaggee 4488 ooff 6611
今天美元 率是
F+匯款手線
今天人民币
十共需要:
款项最慢后天会到,您到时确
认一下。

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 49 of 61
all
Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 49 of 61
中国移动 つ
目前二审,主要是针对刑期和
罚款金额两个部分,金额问题
不大,最主要刑期减轻是关键

CCaassee:: 2266--11662266,, 0066//1122//22002266,, DDkkttEEnnttrryy:: 11..11,, PPaaggee 5500 ooff 6611
-
Privileged and Confidential
Service Agreement
Client), agree to sign the legal service agreement with Law Offices of Yongbing
Zhang (ZYB & Associates LLC, or "The Firm") for asset distribution from the
Fair Fund administrator. The Firm will provide the roll
2.
filing claim form with supporting documents on my behalf with GTV Media Group Fair Fund
b. bying to secure the distribution of my proportional investment fund for GTV media group from
OTV Fair Fund ("the Fair Fued") created by the United States Securities and Exchanges Commis-
sion (SEC) under the File Number of 3-20537;
c. depositing the secured distribution from the Fair Fund to the Firm's client trust account (toast so-
count). if the Firm's efforts result in successfid and favorable distribution for me:
d. maintaining the secured distribution in the client trust account of the Firm until my authorization
to withdraw it out of the trust account
3. Excluded Start
The Firm is not hired to:
1) litigate against any parties regarding your right in GTV Stock or Digital Assets; 2) increase the value of
your recovered investment through making investment in the market or making loens to other parties, which are
beyond our expertise; and 3) other unrelated maters to the Engagement
4. Legal Fees kad payment
I agree to the attorney fee at 1% of the requested distribution refund sought by me, which is
$ at this time, but is subject to change in the course of representation.
3. Generator Law and Dispute Resolution
This agreement is governed by the law of State of Illinois of the United States By entering this agreement,
I give the United States federal or state courts in Cook County of Illinois the exclusive jurisdiction to resolve the
disputes out of the agreement.
AGREED by:
Dare
AGREED by:
Yoogbing Zhang on behalf of ZYB & Associates LLC
Youghing Zhang

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 51 of 61
II!; Iii
NBllttJJ~fill(ftftfffJ.»lftl,f>llf)Vdt.
'fl011~,A\U,
fUU:
U)ft (~A+M•I
~d(fN,1,UJ
ttm m, 17lft-!II. 11.tftlllfVtlQoJBtfMtil'tlldlfl
m,it;tt,'.■-ft\UU1 •
1 UY IIRllll
l. Otl
J.. :nil IJ MtttO ..
1U1 .>-11-4 .!:.llll16·t
ft1f:,t:_HU
~~
{/{.it)·

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 52 of 61
April 10, 2022
•
~ffi/J\lf
2022/4/10, 09:23
tj~ a{J~{u.ldt~::kJ~~9:f :
1~.Pfrfi 1=5 llRnOO?i:lt!l~±m~u~)i'H±:5!tl=H&'.
cosmos@ltk ()/!;~Am. EHt: cosmos, ).ffi\Blffi
ffi, if!H-#8065, ~+#6311, Jllii;~lm~) i'l=filiu
uis:, it=f!m ffi ~~ f" a{] i!lt&: §'I im~~ trfi ~
.~,, #.§..t{~M'iJ£~1=5~ff~~~~Vifi, 1fVifi~*ll
!.@1$8~1iEf.@fo.lcosmos1'l=filiu!fil{!k~it9.Wi'sl,g!i,-J-~
1'1= 9.\iu a{] U ~
:m~~filiua~~~1n~~lfcl15m~. ~1n~111J:En
00>~1$1?1l~A~•~~~i'l=filiul?1l{!kYitZt($, 93~**
~!llia~~f"
http
n
~a ?m!I! )li-tv~ifiliJiijl~ 00 ~tib a{] fiJ. ~ Af H jj/1
ltD%~

CCaassee:: 2 266--11662266,, 0 066//1122//22002266,, DDkkttEEnnttrryy:: 11..11,, PPaaggee 5533 ooff 6 611
dul.Final_Version pot
金額先空筆記事或许振惠客一下大
汇軍计算 台灣選派先空瓣
金額扫日期影先空著不填 !.

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 54 of 61
PURSUANT TO AGREEMENT OF AUGUST 1,

TO: LENDER
•
LENDER'S Email:
FJOM.BOU.OWD.
Y~tol.-1td
IHAl-'-IPl~ttlltbm.A.'lldlla6..Hw~l140
,_.....,
,-.111--. ... ocwt-............. Nlf"dll,lOZO,ll ..... l(f)-
l ......... )"<;Ml .... ~ .. ndol'IJlbtfat.l~--~.ttw""-....-u_.,._
~,-,,.~ .......... - ..l lfr
o.i.-.,..,...,,.?Oll
•

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 55 of 61
M(J_
c~

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 56 of 61
From: Pr e Filing
Date: o Friday, May 22nd, 2026 at 12:04 PM
Subject: ATION, PLEASE REVIE
To
IMPORTANT INFORMATION, PLEASE REVIEW
Your email has been recei\led by the Pro Se Intake Unit of the United States District Court for the Southern District of New York, {This Is not the
United States Ba_nkruptcy Court,)
Documents from prose litigants that meet the required standards for electronic filing will be filed and wlll appear on the ECF docket withln two
business days of receipt (see required standards below). If you send your document by email and It Is accepted for filing, you should not deliver
a hard copy version to the court.
Requirements for Flllng a New Action by Emafl:
Documents must be attached to the emall In PDF fonnat, no larger than~ megabytes;
The complalnt must be signed by the filing party;
•
Fee requirements and Instructions:
•
Please note that your comp la Int wlll not be revlewed until the court receives payment of the flllng fees,
Payment must be made within 30 days of lhe date your case Is assigned a docket number. If rnaUlng payment, please send a
certified check, bank theck, or money order to: Cuhlers Room 260, 500 Pearl Street, New York, NY 10007.
Your payment must include the docket number, which you can leam by cal11ng (212) 805·0175.
If you have not consented to e-servlce, your docket number will also be malled to you, at the address provided on the complaint, in
a form order tMt will Include payment Instructions. If you do not make payment within 30 days of the date a docket number ts assigned to your
case, the action will be dismissed without preJt1dlc.e.
If you cannot pay the filing fees and want to reqllest that the court waive the filifl8 fees, you must email an MP.lication to proceed in
formo oquptris.
Filfng Documents In an Existing case by Emal!:
Documents must be attached to the email In PDF format, no larger than 10 megabytes;
The email and attached document must contain the docket number, filer's name, address, and telephone number;
Documents must be signed by the filing party;
Any additional comments, questions, or other messages In the emall w\11 be disregarded;
Any additional correspol'ldence Included In the email will be disregarded.
For any submission, If your document does not appear on the ECF docket within two business days, It has not met the required standards for
electfontc filing. If so, you must submit your document to the court In paper form by (a) sending your document by mall, or overnight delivery
service, to the appropriate courthouse listed below; or (bl delivering your document In-person to the appropriate courthouse Usted below
between the hours of 9:30 AM to 1:30 PM; or (c) depositing your docutnent after hours In the court's night depository box at the 500 Pearl
Street, NV, NY courthouse.
United States Courthouse
P,o Se Intake Unit
S00 Pearl Street
New York, NY 10007

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 57 of 61
C
Anna ( ) DOCKETING STATUS case #1-23-cr-118(AT)
I would like to know the docketing status on my May 22, 2026 filing -if there is a requirement that has not been met
for the filing to be docketed, please advise.
Thank you.
Regards.
Ann....-..
G-series Investor
China
------- Forwarded Message------
From: •
Date: On Friday, May 22nd, 2026 at 12:09 PM
Subject: Fw: IMPORTANT INFORMATION, PLEASE REVIEW
"
------- Forwarded Message -------
From: Pro Se Filing
Date: On Friday, May 22nd, 2026 at 12:04 PM
Subject: IMPORTANT INFORMATION, PLEASE REVIEW
To:
IMPORTANT INFORMATION, PLEASE REVIEW
Your email has been received by the Pro Se Intake Unit of the United States District Court for the
Southern District of New York. (This is not the United States Bankruptcy Court.)
Documents from pro se litigants that meet the required standards for electronic filing will be filed
and will appear on the ECF docket within two business days of receipt (see required standards
below). If you send your document by email and it is accepted for filing, you should not deliver a
hard copy version to the court.

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 58 of 61
IMPORTANT INFORMATION, PLEASE REVIEW
From Pro Se Filing <pro_seJiling@nysd.us urts,gov>
To
Date M
IMPORTANT INFORMATION, PLEASE REVIEW
Your email has been received by the Pro Se Intake Unit of the United States District Court for the
Southern District of New York. (This is not the United States Bankruptcy Court.)
Documents from pro se litigants that meet the required standards for electronic filing will be filed and
will appear on the ECF docket within two business days of receipt (see required standards below). If
you send your document by email and it is accepted for filing, you should not deliver a hard copy
version to the court.
Requirements for Filing a New Action by Email:
• Documents must be attached to the email in PDF format, no larger than 12 megabytes;
• The complaint must be signed by the filing party;
• Fee requirements and instructions:
• Please note that your complaint will not be reviewed until the court receives
payment of the filing..fu§.
• Payment must be made within 30 days of the date your case is assigned a docket
number. If mailing payment, please send a certified check, bank check, or money order to:
Cashiers Room 260, 500 Pearl Street, New York, NY 10007.
• Your payment must include the docket number, which you can learn by calling (212)
805-0175.
• If you have not consented to e-service, your docket number will also be mailed to you,
at the address provided on the complaint, in a form order that will include payment instructions.
If you do not make payment within 30 days of the date a docket number is assigned to your
case, the action will be dismissed without prejudice.
• If you cannot pay the filing fees and want to request that the court waive the filing fees,
you must email an ll,pplicatlon to proceed in torma pQJJ!W]i.
Filing Documents in an Existing Case by Email:

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 59 of 61
IMPORTANT INFORMATION, PLEASE REVIEW
From Pro Se Filing <pro_seJiling@nysd.uscourts.gov>
To
Date
IMPORTANT INFORMATION, PLEASE REVIEW
Your email has been received by the Pro Se Intake Unit of the United States District Court for the
Southern District of New York. (This is not the United States Bankruptcy Court.)
Documents from pro se litigants that meet the required standards for electronic filing will be filed and
will appear on the ECF docket within two business days. of receipt (see required standards below). If
'
you send your document by email and it is accepted for filing, you should not deliver a hard copy
version to the court.
Requirements for Filing a New Action by Email:
• Documents must be attached to the email in PDF format, no larger than 15. megabytes;
• The complaint must be signed by the filing party;
• Fee requirements and instructions:
• Please note that your complaint will not be reviewed until the court receives
payment of the filing fees.
• Payment must be made within 30 days of the date your case is assigned a docket
number. If mailing payment, please send a certified check, bank check, or money order to:
Cashiers Room 260, 500 Pearl Street, New York, NY 10007.
• Your payment must include the docket number, which you can learn by calling (212)
805-0175.
• If you have not consented to e-service, your docket number will also be mailed to you,
at the address provided on the complaint, in a form order that will include payment instructions.
If you do not make payment within 30 days of the da_te a docket number is assigned to your
case, the action will be dismissed without prejudice.
• If you cannot pay the filing fees and want to requestthat the court waive the filing fees,
in
you must email an i!P-P-lication to proceed fm{lQ!J/2£fil.,
Filing Documents in an Existing Case by Email:

Case: 26-1626, 06/12/2026, DktEntry: 1.1, Page 60 of 61
Respectfully submitted
The undersigned, Anna , declares under penalty of perjury the foregoing is
true and correct to the best of Petitioner's knowledge and belief.
Signature: ~
Certificate of Service
Petitioner certifies that on June 9th 2026, Petitioner submitted this Writ of Mandamus filing
,
to the following parties:
Via USPS:
The Hon. Analisa Torres, SONY District Court
500 Pearl Street, New York, NY 10007 -1312
Nathan Rehn
United States Attorney's Office for the SONY
26 Federal Plaza, 37th Floor
New York, NY 10278
Via email only:
Counsels for the Defendant
• msarafa@sarafalaw.com
• jdratel@dratellewis.com
• jkaley@doarlaw.com
Signature: - - -

Case: 26-1626, 06/12/2026, MDktEntAry: 1.1I, PLage 61 of 61
~ERVIC~-® \
'--"'"•~ "-~
.,
·.,
""'"-~. '
"'apply).'
,rnational destinations.
\ FR
••
,.;:;,t
l
-0~w
·i: :./ -~ /ood7
' ,1... •
C
I £" " - '"!- t✓ w'"
►>
\1• \ '", _ " -,, a<i"> · ,Dc · -o , • .} it,;:} .~;e -~ -1 ..i . i.~O
' --~ ~ ·~•,.'4'~ • 'l_ ~ ~ - - --
:a·~-;;..,"~_:.. ·- ,
·r· • · ·
1 . ,:(_
i'
~ n:.-
\ ,i· --- ~NAT\ONA • . ,'."\';......
~;J.:'"
1,1, I - .
iO:
\,._,_~ _-· I
EXP~;TE~ ~ELIVERY DAY: 06/12/26
I!' __ _.,,. 1
~ ~,-- ~
(>~k
I
\
US t,,Oc$1( ~PP44
\
&vv1
U rvLA./4V
e1
~q
4 \) Fol
iitCvrtL-
~ _j

'(uflLI >-JY (
oov
\,
\
'
~r\NSURED
I