Guo Wengui / Miles Guo — bankruptcy case · ECF #102-1
METADATA
- Defendant
- Guo Wengui / Miles Guo / Ho Wan Kwok
- Court
- CTB
- Case No.
- 22-50073
- ECF #
- 102
- Type
- UNKNOWN
- Filed
- 2022-03-19
FULL TEXT
Case 22:50073:20000110173-KPMedi0301911812213:50ag6119122213:50ag61 of 92
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WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY Case 22GAR73:20Doc-0627B-KFWedD3d19122113:56ag6 2 Page 2 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
1 UNITED STATES DISTRICT COURT 1 APPEARANCES: (BY VIDEOCONFERENCE)
3 ---------------- 3 RANDAZZA LEGAL GROUP 4 LOGAN CHENG f/k/a Shuiyan Cheng, 4 Attorneys for Plaintiff 5 Plaintiff, 5 2764 Lake Sahara Drive, Suite 109
7 MENGUI GUO, 7 BY: JAY MARSHALL WOLMAN, ESQ. 8 Defendant. 8 MARC RANDAZZA, ESQ.
1 2 REMOTE DEPOSITION OF HOWAN KWOK 12 Attorneys for Defendant 1 3 April 1, 2021 13 7500 Old Georgetown Rd, Suite 901
Reported by: 15 BY: JEFFREY GAVENMAN, ESQ.
18 18 Also Present: 1 9 19 Juliet Hooper, Document Technician 20 20 Una Wilkinson, Mandarin Interpreter
4 April 1, 2021 4 AGREED, by and between the attorneys for 5 10:00 a.m. 5 the respective parties herein, that 6 6 filing and sealing be and the same are 7 7 hereby waived. 8 Remote deposition of HOWAN KWOK, held 8 IT IS FURTHER STIPULATED AND ਰੇ before Mary F. Bowman, a Registered Professional 9 AGREED that all objections, except as to Reporter, Certified Realtime Reporter, and Notary 10 the form of the question, shall be 11 Public of the States of New York and New Jersey. 11 reserved to the time of the trial.
1 4 14 AGREED that the within deposition may be 1 5 15 sworn to and signed before any officer 1 6 16 authorized to administer an oath, with 1 7 17 the same force and effect as if signed 18 18 and sworn to before the Court.
Case 22G0073:20Doc-0627B-KFWedD3c10M22t 5ErfterEddBl11912213:56ag6 3 of 92
THE REPORTER: Will counsel answer, as a general proposition, you are required please stipulate that in lieu of to nonetheless answer my questions. And your
answers are going to need to be in words, rather the reporter will instead ask the than in nods or sounds in order to ensure that we
5 have an accurate transcript of this proceeding.
interpretation will be true under the If at any time you need to take a
penalties of perjury, that counsel will 7 break, please let me know and we will do so. But not object to the admissibility of the 8 I would ask that you answer any pending question transcript based on proceeding in this 9 unless it is to confer with your counsel regarding
way . 10 a claim of privilege.
MR. GAVENMAN: Yes. And I would ask that if you don't
MR. WOLMAN: Yes. 12 understand a question, please don't guess. I
THE REPORTER: Do you solemnly swear 13 would be happy to try to rephrase it.
or affirm that the interpretation you will Do you understand that?
give in this deposition will be from English Yes, I understand.
A.
to Mandarin and from Mandarin to English to
the best of your ability? Q. Have you ever had your deposition
THE INTERPRETER: I do. 17 taken previously? 1 9 Yes.
A. 20 How many times?
(). 21 I can't recall. A.
22 Q. Is it more than five?
23 Possible.
A.
25 24 United States? Yes.
A.
HOWAN KWOK, Q. Are there any particular cases you can
called as a witness by the parties, recall in which your deposition was taken?
follows: defamation case and Ha Yieliang defamation case.
EXAMINATION BY Q. Before we proceed, I want to clarify
MR. WOLMAN: one thing, you said before we proceeded that your
Q. Good morning, Mr. Kwok. name is Howan Kwok. Is that correct?
Good morning, sir.
Yes. A.
Q. My name is Jay Wolman and I represent ರ
10 Mr. Logan Cheng who is a plaintiff in a suit 10 name so I can make sure I address you properly and 11 against you in the U.S. District Court for the 11 pronounce it properly. 12 Southern District of New York. A. K-W-O-K.
Q. Can I hear you say your last name?
14 interpreter who will be interpreting my questions 15 to you and your answers back to us. And because A. K-W-O-K -- O-K, H-O-W-A-N, that is my 15 name.
16 of the number of people, we can't talk over each 17 other. Q. I understand. I'm not asking that
17 question. I want to hear you say your last name. Kwok. A.
19 English, please make sure that you hear the 19 Kwok. Thank you. Q. 20 interpreted question and answer in your native 20
21 language in order to ensure that we get the most 21 your name as W-E-N-G-U-I, G-U-O. Are you familiar 22 accurate discourse between us. 22. with that?
MR. GAVENMAN: Objection to form. 24 lawyer, Mr. Gavenman, who may make certain 25 objections. But unless he directs you not to 24 Can you clarify which lawsuit we are talking about?
Case 22G0073:20Doc-0627B-KFWedD3019122113:56aB0119122213:56ag6 4 of 92
MR. WOLMAN: I said this lawsuit.
MR. GAVENMAN: OK.
talk about the immigration status, right?
You can ask this question, but if you go any A. Yes.
Q. Is that a name you use?
Yes. A.
Why do you use that name?
Q.
immigration status, Mr. Kwok? 8 they were actually the pronunciation for the same
9 character, but one is the pronunciation from
middle of the application of political asylum.
10 mainland China and one is the pronunciation in
11 Hong Kong. 11 that you used on your asylum application? A. H-O-W-A-N, K-W-O-K. Q. What about the given name?
A. It is because when I went to Hong Kong Q. Before you mentioned a social security
14 and because the name has been duplicated in some 14 card with a different spelling, is that correct? 15 way, so I changed the given name.
16 H-O-W-A-N, K-W-O-K. Q. What is on -- strike that.
18 issued by a government, either federally or state 18 spelling H-A-Y-U-N, is that correct? 19 in the United States?
Yes. 20 that it's H-O-W-A-N.
A. Q. And what is that identification?
22 H-A-O-Y-U-N for your given name?
A. Howan, H-O-W-A-N. 23 Q. Q. Let me ask again. What is the form of
A. No. 24 identification?
A. Social security card. 25 card. Are you employed?
a lot of companies. And my current employment is
by the State of New York?
No. the -- I am in the broadcasting and to take down A.
the Chinese Communist Party. It is a broadcasting
identification issued by the United States
revolution.
Department of Homeland Security? Q. How much do you get paid for that?
No. A.
Mr. Guo declines to respond to the question Q. What is your immigration status to the
United States?
Amendment of the U.S. Constitution.
He can't answer that question.
13 attorney's advice and refusing to answer that
14 question?
questioning. A. Yes.
17 for -- under -- for any crime by any United
18 States, state or the federal government?
counsel, Mr. Guo declines to respond to the
status is.
question invoking his rights under the Fifth
not he has an identification card. Amendment of the U.S. Constitution.
whether or not there is a prosecution.
objection, Counsel.
Either the government is prosecuting or not. Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 5 of 92 xyz{
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Case 22G0073:20Doc-0627B-KFWedD3d19122113:56aB0119122213:56ag6 6 dfage 6 of 92
the Nevada case? screen.
MR. WOLMAN: The Nevada case we are (Exhibit 1, Amended Notice of
discussing right now. Deposition marked for identification, as
A. They have used translator briefly to of this date.)
go through that complaint to me, you know, once. Q. Mr. Kwok, to the best of your 6 knowledge and understanding, is your presence here I can't read it myself because I don't know how to 6 7 today pursuant to the amended notice of deposition
Q. Are you familiar with the English shown as Exhibit 1 ?
9 A. Yes.
A. I know the alphabet. Q. Thank you. You can close that. Q. And are you able to tell the Mr. Kwok, what did you do to
12 difference between the letters "G-U-O" and 12 prepare for the deposition today? I don't need to 13 'K-W-O-K''? 13 know what you and your attorney discussed. A.
Q. And did you see the English language Mr. Wolman's clarification, but please don't
16 version of the Nevada complaint before it was reveal any attorney/client communications.
17 filed? You can just say generally what
THE INTERPRETER: Counsel, you're we did.
asking before he filed the complaint, did he MR. WOLMAN: I didn't say -- wait,
read the complaint? stop. Please don't change my question. I
MR. WOLMAN: Did he see the English did not say "Generally."
language version of the complaint before it MR. GAVENMAN: OK.
was filed in Nevada. THE INTERPRETER: I still need to Yes.
A. interpret what counsel just has said. OK.
Q. Did you notice at any time that it did A. Yes. And then my --
not contain your name with the spelling K-W-O-K? THE INTERPRETER: Sorry, the witness
MR. GAVENMAN: Objection to form. just said something and he stopped, so I am
I don't remember.
just clarifying with him what was he saying.
Q. Did you observe that it contains the 4 I just say yes. A.
name spelled G-U-O throughout the complaint in Q. That was not a yes-or-no question.
Nevada? What did you do to prepare for today?
MR. GAVENMAN: Objection to form. MR. GAVENMAN: Again, I'll caution
A.
What is the name Miles Kwok?
communications in this answer. A. Well, because any Chinese person A. I have done some normal preparation
11 operating or living in the western world, then we 11 before appearing to court, but I can't tell you 12 would have an English name adding the last name, 12 any more because that would reveal what had been 13 and that's Kwok. 13 discussed between my counsel and myself. Q. Thank you. Q. Did you review any documents to
ાં ર 15 prepare for today's deposition? you a document starting 001. A. No.
TECHNICIAN: Yes, Counsel, would you Q. Did you talk to anybody other than
like that on the screen? 18 18 your attorney about this deposition? MR. WOLMAN: Yes, please.
A. No. TECHNICIAN: Would you like that Q. Does anybody other than the people on
marked as an exhibit? 21 21 this screen know that you are being deposed today?
22 I don't know.
A. Exhibit 1. Q. Have you told anybody that you are
TECHNICIAN: One moment please. 24 24 being deposed today? OK, the document is on the A. I haven't told anyone specifically,
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Transcript of Howan Kwok Conducted on April 1, 2021 21 1 but then the thing is that every day, I will be 1 But now that you scroll down, I can see my 2 doing my broadcasting and during which I said that 2 signature. I don't know whether I have seen this I will be being a witness, but I did not 3 document before or not. 4 specifically say what case. Q. Is that your signature? Q. And in what broadcast did you say you 5 Yes. A. would be a witness? 6 Q. Do you remember --7 A. So it was at the 9:30 GTV program. A. It is my signature, Guo Wengui. This morning? 8 Q. Are you familiar with somebody named Q. Daniel Podhaskie? Yes. 9 A. Q. From where did you broadcast that? 10 ব Vec A. It was not a broadcasting. It was 11 Q. Where were you on December 10, 2020? 12 really just like making a video. It's like those 12 MR. GAVENMAN: Objection to form. 13 one-minute short videos and -- so nine minutes of 13 A. I can't remember. 14 video. But then after nine minutes, we would just 14 Q. Did you meet with Mr. Podhaskie on 15 do one-minute uploading. So it was like that kind 15 December 10, 2020? I don't recall. 16 of a video making. 16 A. Q. You said "we." Who is we? 17 Q. How do you recall the name A. I did not say "we." I said I. 18 Mr. Podhaskie? A. Daniel Podhaskie, he is working Q. Did anybody assist you with that 19 20 recording and uploading? 20 lawyer. He's a lawyer working in the work -- No. A. 21 working. Q. From where did you make that recording 22 Q. Is Mr. Podhaskie your lawyer? 23 and uploading? 23 MR. GAVENMAN: Objection to form. A. It was the same chair and the same 24 A. He's working for New York Golden 25 desk and same background. It's just right here. 25 Spring. 22 Q. Where is that? 1 Q. Thank you. A. It was 1801 Sherry Netherland. 18th 2 Do you have any reason to believe that 3 floor. this is not your signature as executed on Is that your residence? 4 December 10, 2020? Q. I live here. It's not mine, but I 5 A. No. A. live here. 6 Q. Did you understand this document MR. WOLMAN: I'm going to show you --7 before you signed it? 8 Ms. Hooper, a document that begins with 007. MR. GAVENMAN: Objection to form. 9 TECHNICIAN: Yes, one moment please. Yes. A. Would you like this marked as 10 Q. How were you able to understand it? Exhibit 2? 11 A. Because every time he would get a MR. WOLMAN: Yes, please. The 12 translator translating the documents before I document is on the screen. 13 understand it, before I sign it. (Exhibit 2, Defendant Wengui 14 Q. And what is Golden Spring New York? Guo's Verified Statement Pursuant to 15 A. It's a company. Local Civil Rule 26.1 marked for 16 And what is your relationship to that Q. identification, as of this date.) 17 company? Q. Mr. Guo, this says this document is 18 MR. GAVENMAN: On advice of Mr. Guo's 19 your verified statement pursuant to Local Civil 19 personal counsel, Mr. Guo declines to 20 Rule 26.1. respond to the question invoking his rights 20 Have you seen this document 21 under the Fifth Amendment of the U.S. 22 before? Constitution. 22 MR. WOLMAN: And please scroll down. 23 Q. Are you accepting your attorney's A. So, you see, I can only recognize 24 advice and refusing to answer the question? 25 Wengui Guo, my name, and some Arabic numerics. 25 A. Yes. Case 22G0073:20Doc-0627B-KFWedD3c10M22t 5ErfterEddBl119122213:56ag6 8 of 92
Q. On December 10, did you sign this how to answer your question. I don't really know document in the presence of Mr. Podhaskie, a 2 how to. And I don't really want to answer
Golden Spring attorney? 3 irresponsibly so that to be irrelevant to this
case.
communications in this answer.
conversations you had with Mr. Podhaskie, in what Q. Before we proceed, I need to establish
capacity does he represent you?
MR. GAVENMAN: Objection to form.
10 the lawyer for Golden Spring, New York. Is he 10 answer this question. I cannot answer this 11 your lawyer as well? 11 question. MR. GAVENMAN: Objection to form. 12 Q. Does Mr. Podhaskie represent you in
A. Yes. 13 13 any lawsuit? Q. Do you have a representation agreement 14 MR. GAVENMAN: Objection to form.
15 with Mr. Podhaskie? A. I don't recall.
MR. GAVENMAN: Objection to form. 16 Q. Does Mr. Podhaskie represent you for
A. This is between myself and my counsel, 17 17 any matter in which you have claimed the privilege 18 so I cannot answer that. 18 under the Fifth Amendment to the U.S. Q. You can answer whether or not you have 19 19 Constitution? 20 a representation agreement. MR. GAVENMAN: Objection to form.
I don't know. A. 21 I don't know.
A.
22 Q. Does any attorney represent you with
23 represents you personally and not just Golden 23 respect to any matter for which you have claimed 24 Spring, New York? 24 privilege under the Fifth Amendment to the United
25 - 25 States Constitution?
along.
one where it just happened?
Mr. Podhaskie? THE INTERPRETER: Counsel, I think
A. I don't recall. that was a question for you, right?
Q. For what purposes does Mr. Podhaskie MR. GAVENMAN: This litigation is
represent you individually? obviously one of them.
"purpose" is in there, I have to caution you
communications in this answer.
sees fit. A. My answer is that he's a lawyer. 11 A. My lawyer here, my counsel, Jeff.
Q. Do you have him on a general retainer 12
13 for any and all purposes? 13 the Fifth Amendment to the United States
14 14 Constitution in any other lawsuit? 15 general, what does it mean general or not general? ાં ર
him again not to reveal any attorney/client Q. Let me try to clarify. 17 communications about this. I believe that
Mr. Gavenman represents you as a your understanding may come from that. So
19 defendant in this case. For what purposes does please don't reveal any attorney/client
20 Mr. Podhaskie represent you? communications.
21 A. Yes.
form and I'm going to again caution you not Q. In what other lawsuits have you
23 to reveal any attorney/client communications 23 claimed the protections to the Fifth Amendment to in this answer.
A. That's right. That's why I don't know 24 the United States Constitution? I don't recall.
A. Case 22t50073:20Doc-0627B-KFWedD3c10912912913:56ag69119122213:56ag69 of 92
Q. When was the last time before this Spring New York?
month you claimed the protection of the Fifth 2
Amendment of the United States Constitution? 3
question invoking his rights under the Fifth
Amendment of the U.S. Constitution.
advice not to answer?
Yes. A.
Amendment in the last year other than this 9
10 lawsuit? 10 New York limited?
A. I don't recall. MR. GAVENMAN: On advice of Mr. Guo's
12 counsel, Mr. Guo declines to respond to the
13 name? question invoking his rights under the Fifth
MR. GAVENMAN: Objection to form. 14 Amendment of the U.S. Constitution.
A. I don't understand your question. I Q. Are you accepting your attorney's
16 don't quite understand. 16 advice not to answer?
Q. Do you get bills from Attorney That's correct.
A. 18 Podhaskie for the services he renders to you? Q. Did Golden Spring or anyone affiliated
A. I don't know. 19 19 with it take part in the decision to sue Mr. Cheng Q. Do you pay Mr. Podhaskie? 20 20 in Nevada?
No.
Who pays Mr. Podhaskie?
Q. answer without revealing attorney/client
Golden Spring. A. communications, you can answer, but I
24 caution you not to reveal attorney/client
25 Mr. Podhaskie for services rendered to you in your communications.
matter, so because that would involve the
Mr. Guo's personal counsel, Mr. Guo declines 3 privilege between counsel and client, so I cannot
to respond to the question invoking his 4 answer this question.
rights under the Fifth Amendment of the U.S. 5 Q. Which counsel are you referring to?
Constitution. Daniel.
A.
advice not to answer? Spring New York or is he an independent outside
A. Yes. 9 vendor'!
Q. Are you aware that Mr. Cheng had a I don't know.
A. 11 judgment against you in Nevada? Q. Where is the office of Golden Spring
A. That I know. 12 12 New York?
Q. Are you aware that that judgment was 13 A. 61st Street -- sorry, 64th Street. 14 paid on your behalf by Golden Spring New York? Q. And where is Mr. Podhaskie's office?
Yes. A. A. Iseem to have seen him in the Golden
1 Q 16 Spring office, but I think that he might have 17 that judgment on your behalf? 17 other offices as well. But I don't know where
18 18 they are.
counsel, Mr. Guo declines to answer that 19 Q. On the day you signed the verification
question invoking his rights under the Fifth 20 statement marked as Exhibit 2, why did you sign it 21 Amendment of the U.S. Constitution. 21 at Golden Spring?
22 MR. GAVENMAN: Objection to form.
A. That's correct.
25 24 in Golden Spring. I don't ever state that I have 25 signed this document in Golden Spring. I think
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Conducted on April 1, 2021 33 35 1 that you probably have mistaken my testimony. I 1 I don't know. 2 have never said that I signed this document in 2 Q. Please answer the question as stated 3 3 Golden Spring. to the best of your ability. 4 4 A. My answer is no, I can't recall. Q. Where did you meet with Mr. Podhaskie 5 5 to sign this document? Q. Are you currently represented in any A. My answer was that I don't recall. 6 6 matter by an attorney named Aaron Mitchell? 7 7 And why would you just like talking rubbish and MR. GAVENMAN: Not just in this 8 telling me that I signed in Golden Spring. I said 8 matter, Jay? You are talking about any 9 other matter? 0 I don't recall. 10 Q. Did Mr. Podhaskie print out the 10 MR. WOLMAN: Please don't answer the 11 11 document for you to sign? question for him. You are now answering a A. I don't recall. 12 12 question for him. 13 Q. Did you print out the document to be 13 MR. GAVENMAN: OK. He is represented 14 signed as Exhibit 2? 14 in this matter --A. I don't recall. ા ર 1 ર MR. WOLMAN: If you have an Q. Why did you choose Mr. Podhaskie to 16 16 objection, make your objection. Right now 17 notarize this document? 17 you are --18 A. Well, according to law, right? 18 MR. GAVENMAN: Trying to clarify the 19 Q. Why Mr. Podhaskie as opposed to any 19 question. 20 other notary public of the State of New York, is 20 MR. WOLMAN: You're not the deponent. 21 21 my question. A. Well, at the moment, I know at least 22 A. I trust him. 22 three counsel's name is Aaron. So I actually 23 Q. Do you have any other lawyers beside 23 can't remember Aaron, whatever that you are 24 Mr. Podhaskie and Mr. Gavenman? 24 talking about. So that is why I cannot answer MR. GAVENMAN: Objection to form. 25 25 that. So that is why I said I don't recall. 34 36 1 A. Yes. 1 Q. Do you have a representation agreement 2 Q. And who are those other lawyers? 2 with Aaron Mitchell? 3 3 MR. GAVENMAN: Objection to form. A. I don't know which counsel you're 4 A. I don't recall their names because if 4 talking about, which lawyer you are talking about. 5 they are in English, I don't usually remember 5 I am unable to answer this question. 6 them. 6 Q. Are you aware that an attorney named 7 Just like, for example, my 7 Aaron Mitchell has entered his appearance in this 8 counsel today, you may have referred the counsel 8 case on your behalf? 9 9 with another name, but I actually just know him as A. I know there is a lawyer named Aaron, 10 Jeff. And I just call him Jeff. 10 but I don't really know whether there is Aaron 11 But that is only natural because 11 Mitchell or what. I just don't know. 12 my reading ability of English probably is Q. Do you have a fee agreement with the 12 13 equivalent to any one-year-old child in the United 13 lawyer named Aaron? 14 States. 14 A. I know that they may have some such ા ર Q. Can you tell me their names as you 15 thing, but I cannot be sure. 16 best are able? 16 Q. Does an attorney named Aaron send you 17 MR. GAVENMAN: Objection to form. 17 bills for services he renders? 18 A. Well, the thing is like I don't really 18 A. I don't recall. I really don't 19 want to mistaken -- like, for example, the 19 recall. 20 president of the United States, Mr. Biden's name Q. Do you pay any bills to the attorney 20 21 as my counsel, as my lawyer. 21 whose first name is Aaron? I don't really want to make such A. Let me state that clearly, that you 22 22 23 kind of a mistake. It would be rather 23 see I am unable to answer this question is because 24 irresponsible for me to mistaking anybody's name, 24 I don't have a bank account, personal bank 25 and -- as my counsel. And I would rather just say 25 account. I don't make payments. So any payment
Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 11 of vwxyz{|}~~}~y~zy}||zwyzz|
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Case 22:5001:30 - DoOHDZ31KPFiledQ3/119/02/113756086.2 dPage 12 of
A.
Q. Are you presently under investigation, 2 link? Give me one moment. Yes, I see it.
to the best of your knowledge, for tax fraud? 3 I am downloading the file now.
MR. GAVENMAN: On the advice of Counsel, it's asking me for a
Mr. Guo's counsel, Mr. Guo declines to 5 password. respond to the question invoking his rights
MR. WOLMAN: Shoot, sorry about that.
Q. All right. Why don't we do this.
Mr. Kwok, did you review the tax returns that were
provided by your counsel to me in this case? communications he might, my understanding, 10 Yes.
A.
Q. Are you aware that it included certain attorney/client privilege. 12 12 tax returns?
MR. WOLMAN: How is acknowledging an MR. GAVENMAN: Objection to form.
14 A. I don't recall.
committed the crime -- self-incrimination? ો ર Q. Are you familiar with the accounting
MR. GAVENMAN: He is invoking the 16 firm named Janover?
Fifth Amendment is, as is his right to do
SO. 18 financial or accounting consulting firm, but I
You can ask a different question 19 cannot be sure. if you like. 20 Q. Do they prepare your New York State
21 and Federal income taxes? Q. Are you refusing to answer?
Yes.
A. Perhaps.
A.
24 is used in the Internal Revenue Code within the Q. Have you filed taxes for the year
24 2020?
A. Yes.
prepared the tax returns? Mr. Grow declines to respond to the question
I don't recall. A.
4 Q. When did you file these tax returns?
MR. GAVENMAN: Objection to form.
I don't recall. A. question?
Q. Was it before or after March 25?
A. Yes. I don't recall.
A.
Q. How much income did you report to the Q. Did you pay any taxes to New York
10 Internal Revenue Service in your tax return for 10 State or the Federal government for the year 2020?
Mr. Guo declines to respond to the question counsel, Mr. Guo declines to respond to the
question invoking his rights under the Fifth 14 Amendment of the U.S. Constitution.
Amendment of the U.S. Constitution.
any taxes is already known to a third-party, the tax return. 17 the government.
record exception. That doesn't mean he can 19 provide any testimony about it.
answer a question about it. 20 Q. Mr. Guo, are you refusing to answer?
Q. Are you refusing to answer? 21 Yes.
A. Yes.
Q. When your tax returns are prepared, do Just one second. Q. 23 23 you provide your tax preparer all information
up uploaded some documents in a zip file. ટર્ર 24 about your income?
Case 22:5007:30 - DoO5I6231KPFiled@3/119/02/113722113:56:186.3 dPage 13 of
વર્સ 001100000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000 47
counsel, Mr. Guo declines to respond to the information to the United States immigration
question invoking his rights under the Fifth authorities in connection with your application
for asylum?
No. A.
Yes. A. Baker Hostetler?
Q. Have you received any communications 7
from the New York State taxing authority regarding
confused with English names.
10 10 strike that. counsel, Mr. Guo declines to respond to the
question invoking his rights under the Fifth 12 12 lawsuit previously, correct? Amendment of the U.S. Constitution, as well 13 A. Yes.
as attorney/client privilege as a separate
basis for objection. ી ર 15 the law firm is for that case? Q. Are you refusing to answer? 16 I don't recall. A.
A. Yes. 17 Q. Did you receive bills for services
Q. Have you received any communications 18 rendered on your behalf in that case? 19 from the United States Internal Revenue Service or I don't recall.
A. 20 the U.S. Department of Treasury or U.S. Department Q. Are bills paid to whoever is
21 of Justice regarding potential tax fraud? 21 representing you in that case?
22 A. Of course they should be paid.
of Mr. Guo's counsel, Mr. Guo declines to
Who is paying those bills? Q. respond to the question invoking his rights 24 Golden Spring.
A. under the Fifth Amendment of the U.S.
Q. Does Baker & Hostetler or whatever law
Constitution, and once again, another firm is representing you in that case have a fee
objection based on attorney/client agreement with Golden Spring?
A. I don't recall.
Q. Are you refusing to answer? Q. Does any attorney representing you in
A.
this case have a fee agreement with Golden Spring?
I don't know. A. provided false information in a tax return to the 7 Q. Why does Golden Spring pay your bills
United States or to the state of New York? for representation in the Pacific Alliance
9 9 lawsuit?
counsel, Mr. Guo declines to respond to the 10
question invoking his rights under the Fifth
counsel, Mr. Guo declines to respond to the Amendment of the U.S. Constitution. 12 question invoking his rights under the Fifth
Q. Are you refusing to answer?
Amendment of the U.S. Constitution.
A. Yes. A. Yes.
ો ર Q. Are you refusing to answer?
16 knowingly provided any false information in a tax 16 A. Yes. 17 return to the State of New York or the Internal Q. Are you familiar with attorneys named
18 Revenue Service? 18 Chris Rose or Silvestri?
19 I don't recall.
A. 20 Mr. Guo declines to respond to the question Q. Do you recall the name of the attorney
21 invoking his rights under the Fifth 21 who represented you prior to Mr. Gavenman in Amendment of the U.S. Constitution. 22 22 Nevada?
MR. GAVENMAN: Objection to form. Yes.
A.
Q. Have you provided any false THE INTERPRETER: Counsel, did you
say something?
Case 22e500130-Dood50231KPFiledd3/119/02/113722113756g86.4 dPage 14 of
MR. GAVENMAN: I said objection to Q. Where is Golden Spring New York
form. getting the funds to pay your bills?
I don't know. A. Q. Did you have a fee agreement with the 4 4 Q. When Golden Spring makes payments on law firm that preceded Mr. Gavenman in the Nevada 5 5 your behalf, how do you let Golden Spring know litigation? that a payment needs to be made?
A. What name again you said? A. That is all arranged by Golden Spring.
8 Q. By whom at Golden Spring?
9 Counselors, lawyers. A. A. Q. Who paid the bills of the law firm Q. Let me try to do it this way. Does
11 representing you in the Nevada lawsuit against 11 Mr. Gavenman send you a bill? 12 Mr. Cheng? A. I never receive bills that counsel
A. Golden Spring. 13 13 sent to me. Q. Why did Golden Spring pay those bills? Q. Where does he send the bills?
MR. GAVENMAN: On advice of Mr. Guo's A. Send to the lawyer in Golden Spring.
counsel, Mr. Guo declines to respond to the Q. So Mr. Gavenman's fee agreement --
question invoking his rights under the Fifth 17 17 strike that. Amendment of the U.S. Constitution. So Mr. Gavenman's bills go directly to
Q. Are you refusing to answer? 19 19 Mr. Podhaskie? Yes. I don't know.
20 A. Q. What are the -- what is the income of Q. How do you know Golden Spring is
22 Golden Spring New York Limited? 22 paying Mr. Gavenman? I don't know. I don't know.
A. A. Q. How does Golden Spring New York Q. Did Golden Spring have any role in
25 Limited generate revenue? 25 deciding to sue Mr. Cheng?
A. I don't know. MR. GAVENMAN: I caution you not to
Q. What are the assets of Golden Spring reveal any attorney/client communications in
3 this answer.
MR. GAVENMAN: On advice of Mr. Guo's You can answer if you can.
counsel, Mr. Guo declines to respond to the 5 I don't know. A. question invoking his rights under the Fifth 6 6 Q. A judgment was issued against you in 7 Nevada. How did you receive that judgment?
8 A. I did not receive it. question about Golden Spring assets, that is Q. Have you ever seen a copy of the
not a party and, my understanding, is not 10 judgment from the Nevada court against you? your client? How is there a Fifth Amendment 11 No.
A. issue here? Q. Did you ever receive anything in the
13 13 mail from Randazza Legal Group sent to you at the
14 14 Sherry-Netherland? respond.
No. A. MR. WOLMAN: How? Q. Do you receive mail at the
17 17 Sherry-Netherland? that question for you. That's the answer, A. Yes, we can receive mail -- well, I
he is invoking his Fifth Amendment rights. 19 19 want counsel you understand this. You see mail He needs to not respond. 20 20 can be received. But the thing is I really cannot Q. Are you refusing to answer, Mr. Kwok? 21 21 read English and so I won't read anything in Yes.
A. 22 English. I was not able to read anything in
23 23 English. 24 have any bank accounts? So that mails could be received, but I Case 22:5007:30 - DoOSIOZ31KPFileDd3/119/02/113722113:56:186.5 dPage 15 of
you put them in front of me today, I won't be able to read them either. 1 like a representative of Democratic parties and so 2 on and so forth and wanting to come upstairs and
received, but I, myself personally won't read them. presenting sort of threats.
I myself personally did not receive them. ഗ
Who did? Sherry-Netherland, that they know the security ().
Golden Spring. 6 threats that posted, and so therefore, that they A.
8 were very careful about dealing with all kind of 8 documents and the source of documents and so that
Sherry-Netherland Hotel directed to you into the
10 hands of Golden Spring? 9 would have special arrangement between them and A. I don't know. 11 10 Golden Spring legal team.
12 is about this -- it's like a warfare nation is
13 getting your mail? 13 targeting me as an individual.
14 Q. So to be clear, before you look at any
15 the lawyer in Golden Spring, Daniel, would have 15 piece of mail, someone at Golden Spring is reading 16 talked to me and told me they received the 16 it first, correct? A. Not necessarily. 17 whatever. And then they would need to get the 17 18 translator and translating those letters, so that 19 I would know about those letters. Q. How is it then determined that you
19 need to have it, a piece of mail, translated for
Well, you see it will be -- you know 20 you? I don't know. A. 21 that at the present time, there are 60 some lawsuits 21
22 going on and they were involved because of the CCP's 23 threat against me, the Chinese Communist Party 23 that. 24 threat against me, and they have done all these kind Is everybody employed by Golden Spring 25 of restricted warfare against me, threatening me. 25 New York a lawyer?
And so, you see, they sometimes A. No.
would send me things or letters probably with
Is Golden Spring New York a law firm? O. toxins inside, threatening letters about my death
No. A.
and about my -- anything that is threatening to my 4 Q. So any time, for example, Mr. Gavenman
sends you a letter or a bill, Golden Spring gets
So that is why the things received would it before you do?
A.
have to go through some security teams and security 7 I cannot be sure. people to make sure that whether it has contained
Q. How would you find out? 9 any toxicity, whether it is any threatening letters, MR. GAVENMAN: Objection to form.
10 whether it should be reported to the police or THE INTERPRETER: Counsel, were you
11 whether it should be dealt with by the legal people. saying something?
12 And then this if some needed for me to know, then 13 they have to go through the translations and all MR. GAVENMAN: I just said objection
to form. 14 kind of protocols. So it is rather complicated. But he can answer.
16 are times that there are documents of thousands of 17 pages, documents sent to me from unknown part of 16 Golden Spring would contact me or sometimes the 17 lawyer would contact me. 18 the world from I don't even know where, and those Q. Who are the nonlawyers at Golden
19 documents would have a lot of like threatening 19 Spring who would contact you? 20 language, sometimes contain perhaps innuendoes and MR. GAVENMAN: Objection to form.
21 implications and so on and so forth. I cannot recall.
A.
23 pretty girls downstairs at the lobby and claiming 23 funded by the Chinese Communist Party? 24 that they have documents for me and sometimes Of course not.
A.
Case 22:5007:30 - DoOSIOZ3IK PFiled Q3/119/2254 Enteried 03/113722113:56:16 of Page 16 of
anyone in the People's Republic of China? wanted to take a quick break, but I just have a
I don't know. A. couple of questions before we do that.
A. G-E-T -- T-E-E-R, yes. certainty that the Chinese Communist Party does 4 Q. What is that device you were holding
not fund it when you previously testified that you
in your hand just a moment ago? do not know its income sources?
My cell phone. A.
And what kind of cell phone is it? 0. know is that Golden Spring had been on the list of 8 Apple.
A. 9 the at risk entity made by the Communist Party and And when did you -- when was it
Q. 10 also as I know that Golden Spring sometimes will 10 purchased? 11 be rejected by bank for having a bank account with One week ago.
A. 12 the bank. And who purchased it?
Q.
13 I don't know.
A. 14 myself and Golden Spring was also being listed by Q. How did it get in your hands?
15 the Chinese Communist Party as a number 1 national It's in the office.
A. 16 enemy. And there are lots of employees in the Q. Some unknown person left it for you in
17 Golden Spring disappeared and arrested in China, a 17 an office, is that what you are saying? 18 lot of videos of such have been circulated online A. Well, I don't know who actually got
19 and that is really a very basic knowledge to 19 it. 20 everyone. What happened was I told the
21 21 lawyer, I said my phone was hacked again because 22 Golden Spring that you state were arrested or 22 you see my phone always gets hacked, nearly every 23 disappeared? 23 week was hacked. MR. GAVENMAN: Objection to form.
A. At this point, I actually don't recall 25 25 so I need to have a new phone.
1 their names, but then there are lots of such Who paid for the phone? Q. 2 videos and information circulated online. You can 2 I don't know. A. just have a search for it. 3 Q. Does it have a cellular data plan?
Q. You previously testified that you made
I don't know. A. a video this morning and uploaded it. On what 5 Q. In whose name does the cellular data
system did you upload it? 6 plan exist?
GTV Geteer.
A. I don't know.
A.
9 9 now? On camera? spell that. I can only tell you the Chinese
A. name is GTV Geteer. 11 Turn it around.
Q.
confirming.
THE INTERPRETER: I don't know. I am 13 see the data carrier? Can you hold that up to the ો ર 14 camera? Closer. Can you get within inches of it,
16 15 please?
17 me to find out the name? MR. GAVENMAN: What is the possible relevance of what's on his home screen? I
Sure. Q. actually really object to this. What are we
A. Because I don't have anything in here, doing with his personal home screen and his
20 so I just really need to -- note paper, nothing, phone? There is no reason he has to be
21 so I just need to go and check. G-E-T-E-R.
22 showing his personal home screen on his
23 G-E-T-E-E-R? telephone.
OK. A.
the carrier is. Case 22:5001:30 - DoO5I6231KPFiled@3/119/02/113722113:56:16.7 dPage 17 of
1 OK, I can't read it. In the 1 phone? 2 upper left corner, what are the letters? 2 A. I don't know. 3 No letters. A. 3 Q. Do you text anyone from that phone? 4 Q. Does it say "AT&T" or "Verizon" or -- 4 A. No, I don't know. 5 No. A. 5 Q. Do you call anyone from that phone? 6 -- T-Mobile? Q. 6 A. I don't know. 7 No. A. 7 Q. Does anybody call you on that phone? 8 Q. I'm going to ask that you do a screen 8 A. I don't know. 9 capture of the home screen. 9 Q. Without revealing the contents of any 10 MR. GAVENMAN: No, no, we are not 10 conversation, have you spoken to Mr. Gavenman on 11 doing that. We are not doing that. Come 11 the phone? 12 on. 12 A. No. 13 This is ridiculous. He doesn't need 13 Q. Prior to today, have you ever spoken 14 to do a screen capture of his personal cell 14 with Mr. Gavenman? ] ર phone screen. That's just -- we are not 15 A. I don't recall. 16 doing that. 16 Q. Did you go down to Baltimore to meet 17 MR. WOLMAN: Jeff, he brought it to a 17 with Mr. Gavenman? 18 deposition. 18 A. No. 19 MR. GAVENMAN: You had him get it for 19 Q. Did Mr. Gavenman come up to New York 20 his deposition. He is not looking at it 20 to meet with you? 21 other than to tell you one name of an app or 21 A. No. 22 whatever that was. 22 Q. How do you communicate with 23 He is not doing a screen capture 23 Mr. Gavenman? 24 and sending it to you. It's not 24 A. I don't recall. 25 happening. 25 Q. Did you prepare for this deposition --
1 Q. What is the phone number that someone 1 strike that. 2 could use to call you on that phone? 2 Did Mr. Gavenman assist you in 3 MR. GAVENMAN: That's another thing 3 preparing for this deposition? 4 I'm going to object to. He doesn't have to 4 A. Yes. 5 answer that. 5 Q. Without revealing the contents of any 6 There is no reason he has to give 6 of that preparation, did you meet in person? 7 his personal cell phone number on this 7 A. No. 8 transcript. There is no possible 8 Q. Through what means did you communicate 9 reason. It is harassing. There is no ರ with Mr. Gavenman? 10 reason for this. Let's move on to 10 A. I don't know what kind of a form that 11 relevant questions. 11 was. 12 It has been two hours and 15 12 Q. Did you have a phone call with him? 13 minutes of a marathon session and you 13 A. No. 14 haven't gotten to relevant questions 14 0. Did you have a video meeting like this ાં ર yet. 15 with them? 16 Q. Please answer the question. 16 A. Yes. 17 MR. GAVENMAN: You don't have to 17 Q. And how did you get the link? 18 answer what your current personal cell phone 18 A. Arranged by the lawyer. 19 is. 19 Q. How was it transmitted to you? 20 MR. WOLMAN: I'm allowed to find out 20 A. I went into the room and the 21 who is paying the bill for his personal cell 21 connection was made. 22 phone as you represented. 22 Q. How did you know the URL to connect? 23 THE INTERPRETER: Counsel, what 23 A. I don't know about the URL. It was
25 question should I be interpreting? Q. What is the phone number for that 25 Spring. 24 all connected by the lawyers and the Golden
Case 22:5007:20 00000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
Q. For today's deposition, how did you In connection with your 67
obtain the URL on the device you were using to 2 application for asylum, did you state that you or
broadcast today? any member of your family committed any crime in
A. It was arranged by the lawyer in the United States?
No. A. Golden Spring.
Q. When did you apply for asylum?
literally in that room this morning at September 2017. A.
A. Well, when I stepped into the room, submit any false information knowingly in
10 the room was already empty and everything is 10 connection with a tax return to the Federal 11 already connected. It's ready. I don't -- I did 11 government or New York State'? 12 not see anyone. MR. GAVENMAN: On the advice of
Q. Who literally pressed on the link to Mr. Guo's counsel, Mr. Guo declines to
14 connect? respond to the question invoking his Fifth
15 Amendment rights under the U.S.
16 in. Constitution.
Q. And how did the link get on to the Q. Are you refusing to answer?
18 device that you pressed? Yes.
A. I don't know.
A. Q. In connection with your application
Q. Does your phone have an e-mail account 20 for asylum, did you invoke your rights under the 2.1 associated with it? 21 Fifth Amendment to the U.S. Constitution? A. I don't have e-mail. 22 A. I don't understand your question.
Q. Have you ever had an e-mail account? Q. With respect to your application for
24 24 asylum, did you claim the protection of the Fifth 25 school. Even though the Chinese Communist Party 25 Amendment as you are doing now?
1 fabricated the information that I have lots of A. Istill don't understand that
2 e-mail addresses, I actually have not one. I have 2 question.
Q. Did you refuse to answer any questions
Q. So are you saying that there is no on your application for asylum on the grounds that
e-mail account associated with the video upload 5 it would incriminate you in a crime?
A. I still don't understand the question.
That's correct.
Q. Did you refuse to answer any questions
Q. Why don't we take a break. on your asylum application?
Q. Mr. Kwok, previously you testified 10 question. 11 that everything that -- your application for Q. Did you apply for asylum?
12 asylum I guess was accurate, correct? 12 A. Yes.
Yes.
Q. Were there questions? Q. Do you recall filling out a form I589? 14 Yes.
A. A. No, I don't recall. । ਦ Q. Did you answer all those questions?
A. Yes. 17 application for an asylum that states, "Have you Did you refuse to provide any Q.
18 or any member of your family included in the 18 information in answering those questions? 19 application ever committed any crime and/or been 19 A. I don't understand. 20 arrested, charged, convicted or sentenced for any Q. Did you give all of the information
21 crimes in the United States, including for an 21 that was requested on your application for asylum?
A. I don't recall. MR. GAVENMAN: I'm going to caution
24 you not to reveal any attorney/client
25 strike that. communications that may have informed your
Case 22:5007:30 - DoO5I6231KPFiled@3/119/02/129122113:56:18 9 dPage 19 of
required or what you provided. l objection. That didn't fix the issue at
A. Yes. Yes, I answered yes. all. The only way to have any knowledge or
Q. Do you know if you have a particular understanding about what he is required to
obligation to update the information provided in
connection with your asylum application?
MR. GAVENMAN: Objection, objection. 6 false. What he knows is what he knows.
The only way he would have any understanding 7
of that is through attorney/client 8 Jay? How would he understand what the U.S.
communications. He can't answer that law requires? Come on.
without attorney/client communications.
11 11 you are saying immigrants have no obligation that assessment. 12 12 to know the law?
14 question on the advice of counsel? 14 understanding from counsel about what the Yes.
A. 15 law requires.
17 information to the U.S. Government in connection 17 established that he used an attorney. 18 with your application for asylum? MR. GAVENMAN: You know he was
MR. GAVENMAN: And this -- I'm going 19 represented by an attorney.
attorney/client communications. 21 21 fundamental question, what in the world
22 22 are you talking about his immigration
23 23 application, his asylum application? attorney/client communications. 24 MR. WOLMAN: Mark, quiet.
MR. WOLMAN: Jeff, I'm asking what he MR. GAVENMAN: Mark, do you want to
gave. Don't coach your witness.
MR. GAVENMAN: That's not coaching my MR. RANDAZZA: No.
witness. You asked if there was ever a 3
supplement. You don't know if it is on his out-of-your-jurisdiction practice, go ahead.
behalf, what he did. This asylum application has no
I said don't reveal any relevance to this proceeding whatsoever. I
attorney/client communications and don't know why you're asking about it and
that's it. That's the instruction. I'm getting close to instructing the witness
It's not anything obstructive. it's not to answer any more questions about it.
Just answer the question.
I don't recall. A.
Q. Have you withheld any information from
15 U.S. immigration authorities that you were MR. WOLMAN: Stop coaching.
17 that's an objection based on privilege.
way he would have any understanding of what 18 That's not coaching.
19 19 BY MR. WOLMAN: counsel.
Q. Mr. Guo, answer the question. MR. WOLMAN: I will rephrase.
22 represented by counsel in that proceeding.
23 any information you are required to provide with You know he is getting advice from counsel
24 the immigration -- what the requirements are. You are starting Case 22e500130-Dood50231KPFiledd3/119/02/113722113756g80 dPage 20 of
attorney/client communications like you're 1
going to testify about the crimes you did or
Q. Mr. Guo, answer the question. Amendment?
is invoking the Fifth Amendment. We are not
objection. He can't answer the question 7 addressing any bit of his income or taxes or
without attorney/client communications. 8 anything like that.
10 BY MR. WOLMAN: strike anything. Thank you.
Q. Answer the question? 11 Q. Mr. Kwok, are you refusing to answer
12 12 the question? know if I interpreted that question or not. 13 A. I don't. I don't have. Very simple
14 14 answer. I don't. question?
Q. Do you have any assets?
17 information that you were required to provide U.S. counsel, Mr. Guo declines to respond to the
18 immigration authorities? question invoking his rights under the Fifth
MR. GAVENMAN: Same objection. Amendment of the U.S. Constitution.
A. I don't understand this question Q. Are you refusing to answer?
A. Yes.
23 authorities whether or not you have committed tax 23 wearing? 24 fraud? MR. GAVENMAN: On advice of his
25 A. A. No. But I have never committed any counsel, Mr. Guo declines to respond to the
tax fraud. So why would he I need to tell them
question invoking his rights under the Fifth
Amendment of the U.S. Constitution.
Q. If you have not committed tax fraud, 3 Q. Are you refusing to answer? are all of your income tax returns that you've 4 Yes.
A. submitted to the U.S. Government in the State of
New York accurate? in a tea glass. Who paid for the contents?
A. Golden Spring.
counsel, Mr. Guo declines to respond to the 8 Q. Does Golden Spring buy your groceries?
question invoking his rights under the Fifth 9 Sometimes, yes. A. Amendment of the U.S. Constitution.
11 11 groceries? that he never committed tax fraud.
13 counsel, Mr. Guo declines to respond to the
going to testify about it. 14 question invoking his rights under the Fifth
MR. WOLMAN: He just did. ો ર Amendment of the U.S. Constitution.
16 Q. Are you refusing to answer?
testify anymore about it. 17 A. Yes.
18 Who pays for your clothes? Q.
19 Golden Spring.
A. protections of the Fifth Amendment or you
Q. are not. 21 21 clothes?
invoking the protections of the Fifth Mr. Guo declines to respond to the question
Amendment.
MR. WOLMAN: You can't do it on a invoking his rights under the Fifth
Amendment of the U.S. Constitution. Case 22:5001:30 - DoO5I6231KPFiled@3/10/02/254Enteried003/113:56:16:1 dPage 21 of
Are you refusing to answer? O. Please, please. ().
Yes.
power. Sherry-Netherland residence right now?
Yes.
right now.
Q.
this deposition is paused for right now.
Are you married?
Yes. A. mute, go off camera. I will be joining the
Q. Where does your wife live? court line momentarily.
She lives in her place.
Q.
A. I can't tell you her information.
14 That is about her. MR. WOLMAN: We just had a conference
Why not?
(). with the judge in which it was indicated
17 you are asking exactly what the CCP wanted to ask regarding the invocation of the Fifth
18 and you representing Cheng Shuiyan's case and that Amendment privilege as has been done here
19 is because you are a hooligan counsel representing today. And that if the judge finds that it
20 the CCP and all the questions you are asking were has been overbroad, that I would be
21 irrelevant to the case, but threatening to the permitted to ask questions regarding assets
22 life -- the safety of my wife and that is exactly at a separate continued deposition date.
23 what the information that -- what the CCP wanted And so what we are going to do right
24 to know. So I can't tell you that. now is move beyond some asset-related
past, all this time that it was CCP, I am CCP's 1 questions. 2 number one enemy, and all this time that there were 2
3 so many cases, such as like the Department of 3 interpret that part first. 4 Justice, Higginbotham being bribed, and Elliott Q. You indicated that your wife does not
5 Broidy being bribed, and they were also like trying 5 live with you. Do you have any children? 6 to kidnap me or arrest me or hurting me, and then 6 MR. GAVENMAN: Objection to form. trying to suss out all the information about me and
You can answer.
A. A son and a daughter.
Q. What are their names? 10 that you are asking me were exactly what the CCP 10 Guo Quiang, Guo Mei. A. 11 wanted to know all the time online and getting
12 people to try to find out this information. Q. Do either of your children live with
13 13 you? 14 about the case that is involving Cheng Shuiyan. And 14 No. A. 15 all this time you were just helping the CCP, sussing ાં ર Are they over 18? Q. 16 out my information and trying to hurt me and trying Yes.
A. 17 to harm me. Q. Have you discussed your litigation,
18 18 either in Nevada or this case with Mr. Cheng, with 19 is the least I can do to protect my family, I am 19 either of your children? 20 not answer your question. In fact, you are not A. No.
21 even a hooligan counsel, lawyer -- 21
22 22 underlying Nevada case with anyone else other than 23 please. You are pausing. 23 your attorneys?
A. No.
Case 22:5007:30 - DoO5I6231KPFileDd3/119/0254 Enteried:00118822113:569:86:2 of
Sherry-Netherland residence with you right now? that our -- we are strategic partners.
A. The hotel security and then also the Q. How were you strategic partners?
cleaning people, cleaning team of the building. A. Well, we are partners in having the 4 common goal of eliminating the Chinese Communist Q. I'm assuming you have not discussed 4
this case with any of them, correct? Party and telling the truth to the west.
A. Yes. That's correct. Q. Sorry, do you have a formal business
Q. And I apologize for this question, but relationship with Mr. Bannon?
do you have a girlfriend or boyfriend with whom A. No.
A. No. 10 10 Mr. Bannon?
12 understanding you also lived on a boat this relevance does any of this have --
13 summer? A. Yes.
Q. Did anybody live on the boat with you? to anything relevant to this case. I've let
A. Yeah, there were many. Like there are a whole bunch of questions go here, but you
17 eight or nine crews. can't possibly tell me there is some reason
Q. Only crew members lived on the boat? to ask these questions other than some
A. Well, there were guests, there were harassing purpose.
20 guests of the owner. So sometimes they were -- If you have another purpose, we
21 and they were there -- too. I don't know. can discuss it, but there is no way this
(Audio issue; reporter is relevant to the case.
clarification) Q. Are you still in communication with THE INTERPRETER: OK, I'm done. 24 24 Mr. Bannon? 25 A. Yes, we are still in communication,
A. Well, I am not the owner of the boat. 1 1 yes. So I can't -- I'm unable to answer that.
How are you in communication? Q.
Q. Did Steve Bannon live on the boat this 3 Phone calls. A.
past summer? Q. Do you call him or does he call you?
A. For a period of time. MR. GAVENMAN: Unless you agree with 6 the representation -- we can go off the Q. So you remember one person. Who else 6
Who were these others?
witness. I will be happy to talk off line I don't recall.
A. if there is any sort of basis why this is
11 relevant, OK, we can proceed.
12 Mr. Bannon and not the others? But you are just harassing him
I don't recall. A.
Q. Did you discuss your litigation with irrelevant. You have been doing that
15 Mr. Cheng with Mr. Bannon? for most of the deposition. What
A. I don't recall. does -- how he calls or doesn't call
17 Steve Bannon have anything to do with Q. If we were to ask Mr. Bannon, would he 17 18 have any information about your lawsuits with this case? Come on.
A. I don't know. 20 recall but your client testified that he
21 doesn't take phone calls. So now he just
22 Mr. Bannon? did.
A. Well, we had the common goal of MR. GAVENMAN: He didn't testify that 24 eliminating the Chinese Communist Party and let he doesn't take phone calls. He didn't
25 the public know about the truth of the virus. And testify that he doesn't take phone calls.
Case 22:500730-000310291K PFiled 03/110/02/254Enteried:001129/22113:56:1863 df age 23 of
MR. WOLMAN: I'm exploring the prior and also it is a kind of a threat to, testimony.
talking about Steve Bannon, his relationship
and my friend.
with Steve Bannon. You are trying to find You see a lot of such deposition
8 the point of it? That's what you are doing? 8
You can ask that question.
10 10 done a lot by Cheng Shuiyan himself. 11 Bannon and his partnership, things like 11
12 that -- that's what you have been 12 information is going to be posted online 13 asking, which is not about phone calls, 13 about, for example, my clothes, my way 14 you haven't made a representation why 14 of life and then my family, my friends, 15 this is relevant so if you want to ask a 15 it's really a form of serious threat to 16 question about phone calls, go right 16 the safety of the irrelevant third-party 17 ahead. But don't mischaracterizes 17 to this case. 18 testimony. And you can ask that And I strongly request a phone
19 question. That's enough with Steve 19 call to the judge to let him know or her 20 Bannon. It this has no possible 20 know that this is a threat to me and my 21 relevance. 21 friend.
23 weren't doing speaking objections. 23 the questions surrounding my clothes, my
25 happy to go off the record. As I said that, 25 daughter and Mr. Bannon, this is really
you went forward to not going off the the circle of my life and this is the 2 record. I responded to what you said. I 2
welcome going off the record?
4 check, that is exactly the questions the
hang on. May I actually make a line of information the CCP always
recommendation, suggestion to my counsel,
collect.
ರ 9 to me, it is a seriously exposing my 10 tell you that I am seriously uncomfortable, 10 person to great danger and great threat. 11 uneasy because I feel like the questions 11 That is why I feel like this kind of 12 they are posing to me has not been relevant 12 question, the line of question is 13 to the case of Cheng Shuiyan and it is 13 actually bearing malice and I wish to 14 really that the questions were asked of me 14 make this known to the judge and I wish 15 were about my friends, my family, and it is 15 my counsel would help me to contact the 16 something that the Chinese Communist Party's 16 judge and let them know that. 17 line of questions. MR. GAVENMAN: And I agree. And I
19 uncomfortable because I feel like it is 19 harassment. Any questions about Bannon, it 20 already posing threat to my own safety and 20 is really not relevant, who is living on the 21 the safety of my friends and family. 21 boat, it's really not relevant.
23 call the judge about that to tell them 23 would move on to the Nevada litigation. 24 that I am very uneasy about that? 24 If you don't, if you keep on this line
25 25 of questioning, I will go to the judge
Case 22:5001:30 - DoO5I6231KPFiled@3/119/02/113722113:56:16:4 dPage 24 of
I don't recall. and go right back to her.
A.
you know it. You told the junk we would 3 United States?
go to the Nevada litigation, let's go to MR. GAVENMAN: On advice of counsel,
Mr. Guo declines to respond to the question
MR. WOLMAN: Can the reporter read invoking his rights under the Fifth
Amendment of the U.S. Constitution.
Q. Are you refusing to answer?
Yes. A.
Q. Mr. Kwok, do you call Mr. Bannon or Q. You said you met Mr. Cheng once. When
11 does he call you? 11 was that? A. I don't recall. 12 A. It will be around October 2017.
Q. What device do you use for these Q. And what were the circumstances of
14 telephone calls? 14 that meeting? A. I don't recall. 15 A. So it was at the time that, in fact,
16 16 that there were a number of people also present 17 you showed us earlier? 17 including his personal employee at the time, Lude
No. A. 18 Wang Ding Gang, and then other people name Yang
Q. What is your highest level of 19 Jian Li and the Han Lian Chao. 20 education? We all met in Washington DC at K
Middle school.
A. 21 Hamlet Hotel and he wanted to -- wanted me to sign
Q. When was the last time you held a job? 22 and to support his anti-Chinese Communist Party
I don't recall. A. 23 campaign and he told me that he respected my
24 24 effort and that he showed his encouragement to my 25 job? 25 anti-CCP activities and -- and then also he asked
me to sign a lot of newspapers.
counsel, Mr. Guo declines to respond to the 2
question invoking his rights under the Fifth 3 any direct communications with him after that?
Amendment of the U.S. Constitution, and 4 MR. GAVENMAN: Objection to form.
Mr. Wolman, we have established we are not 5 A. No.
going to go any further with income Q. Do you recall making a video about
Mr. Cheng?
MR. WOLMAN: Let me ask this one, let A. I made a video on the 5th of June
me ask this one. 9 2018.
Q. What was the last job that you held Q. And why did you make that video?
11 that you won't invoke the Fifth Amendment A. So it was in 2018, March and April,
12 privilege for? 12 Wang Ding Gang who is Cheng Shuiyan's employee and
MR. GAVENMAN: I need to object -- to 13 together with Cheng Shuiyan they created a media
the extent you can answer that based not on 14 called the Voice of Freedom. And then on YouTube, an attorney/client communication, you can ો ર 15 that they created a lot of the video supporting me answer. 16 16 and then also the corruptions of the Chinese
17 17 communist party.
19 19 April, Wang Ding Gang told me that there was
20 20 someone from Bejing with a government background
answer revealing any attorney/client 21 visiting Cheng Shuiyan and representing him
communications. 22 expensive gifts such as expensive Moutai and then
A. I actually don't recall. 23 telling him not to support me. And so not to
Q. What is the job you have held for the 24 support me on the platform of Voice of Freedom. 25 longest period of time? So is that he will -- Cheng
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Case 22e500130-Dood50231KPFiledd3/119/02/113722113756g86.6 dPage 26 of
And in fact, his Hong Kong that would be the cell phone that was hacked which partner also had in contact with me and giving me 2 stored the documents of Cheng Shuiyan.
such documents as well and then all those
documents and the information I stored in the Twitter account as well, and when that happened, I
computer and the cell phone before and which were
tweeted out and sending out messages that telling hacked and all been destroyed. Otherwise, I would 6 my phone was hacked, the documents were hacked,
have them in my cell phone and my computer. 7 and so the Twitter message and videos, I send the
message out. of bank documents and also his criminal record --
Q. When did you throw out these phones? 10 documents and records in mainland China and his A. Around August or September 2018. I'm
11 lawyer provided them to me and I have -- I had all 11 not saying that I dispose all the phones within a 12 of them. 12 day. Well, sometimes here, sometimes there. Q. OK, what was the name of this lawyer? 13 13 Sometimes -- hang on. A. And I don't recall it now.
1 ર 15 sometimes later, sometimes earlier, it's because 16 business partner? 16 those cell phones, once they were hacked -- A. I don't recall that now either. 17 17 sometimes they were just being hacked, but Q. When did this alleged hack take place? 18 18 sometimes the entire phone was on fire.
19 So to keep all these phones here would
20 employee, personal employee, Marco, made the 20 really be like threatening so that's why I just 21 attack on me on the platform Geteer, and since 21 disposed of them. 22 then, my cell phone was hacked daily. In fact, Q. I'm a little confused because isn't it
23 really daily. 23 true that the HBO piece aired on November 15,
24 24 2017, months before the video of May 2018 -- 25 2018, Cheng Shuiyan and his personal employee, 25 sorry, June 2018?
1 Marco, being -- attacking me and because of that A. So what -- maybe there is some mistake
2 attack and I changed my cell phone was hacked either and I did not say that the cell phone was hacked
every day or every other two days. So basically at ను in those cell phone displayed in the HBO
that time, I need to change cell phone nearly every 4 interview.
Q. And the documents were on this cell interview, I have displayed the cell phones that
phone and the computer, you say? have -- so many of the cell phones being hacked.
A. Yes, it was on that cell phone. So I was just saying that my cell phone
Q. And where is that cell phone now? 9 9 was already hacked during that time, but the peak of
A. All thrown away. Because I could not 10 the hacker was happening in 2018 between May and 11 open them anymore and I could not use them 11 August. 12 anymore. Q. OK. And you say you probably disposed
Q. And where is that computer now? 13 13 of the phone that had the documents regarding
A. I did not use computer. I was 14 Mr. Cheng at some point in August or September of 15 actually just using cell phone. I was talking 15 2018, correct? 16 about just cell phone. Yes.
A.
17 Q.
18 cell phone? A. Let me think, let me think.
20 and MSN Messenger. mind if I clarify with the witness one word
In fact, that HBO had made an that I'm not quite sure I caught?
22 interview, had interviewed me, and then during MR. WOLMAN: Sure.
23 that interview is -- you can check on those 23
24 videos, during that interview, I placed on the 24 though those documents were destroyed, however, a
Case 22:5007:20 - DoOSIO231K PFiled 03/11/02/22113:56:18 7 dPage 27 of
Conducted on April 1, 2021 101 103 1 to the network, on the Geteer platform. So if you 1 A. I don't have any recollection. 2 were to make a such, you can find those documents. 2 Q. Who told you to dispose of the phones? 3 3 Q. When was it you first decided to sue A. Myself. 4 4 Mr. Cheng? Q. Did anybody ever tell you not to 5 5 dispose of phones? A. So I really cannot quite recall from 6 I don't recall. 6 June, July, August, you know, during that period A. 7 Q. Do you have any awareness of an 7 of time, he made serious attacks towards myself 8 and my family, full of malice and including he 8 obligation to preserve documents in anticipation 9 9 himself, his employee, Marco, every day just of litigation? 10 incessantly just creating attack towards me. It 10 MR. GAVENMAN: Objection. 11 has brought so much harm and so much destruction 11 To the extent you can answer that 12 to my life and my family. 12 without it being based on 13 So I really cannot recall exactly when 13 attorney/client communication, you're 14 14 that I decide to sue him, perhaps in May or August, welcome to answer it, but please don't 15 around that time. 1 ર reveal attorney/client communications. 16 16 Q. When did you hire attorney Christopher A. My answer is no. 17 Rose and/or the law firm of Jolley, Urga, 17 Q. Is there any reason nothing about your 18 Woodbury, Holthus & Rose? 18 video or these documents were mentioned in your 19 A. So I must also clarify that, you know, 19 August 9, 2018 complaint against Mr. Cheng in 20 Nevada? 20 I actually don't remember the names, the names of 21 the counsel or the names of the firm. All these 21 MR. GAVENMAN: Again, I strongly 22 names that you just talked about, I have no 22 caution you not to reveal any 23 concept whatsoever. 23 attorney/client communications. 24 24 But do you mind if I go to the To the extent any understanding 25 bathroom? 25 comes from attorney/client 102 104 1 1 Q. That's fine. communications, you should not reveal 2 2 Wait, strike that, let's answer them. 3 3 the question. When did you hire the law firm that To the extent you can answer it 4 filed the Nevada suit? 4 without revealing, you can. 5 A. I cannot recall the specific time. 5 A. No. 6 Q. OK, we can take a five-minute bathroom 6 Q. You mentioned the use of MSN 7 break. Messenger. What is the Microsoft account 7 8 (Recess; 2:31 p.m. to 2:40 p.m.) 8 affiliated with that? 9 9 Q. Mr. Guo, do you ever attempt to MR. GAVENMAN: Objection to form. 10 recover the data from any of these phones you 10 A. Well, I have over a hundred of a cell 11 claim were hacked? 11 phone. I really cannot recall any of those. A. Well, it was never recovered 12 12 Q. Are you aware that --13 successfully. 13 A. So when I'm talking about hundreds of 14 Who attempted to recover it? 14 cell phone I use, that would be the situation to Q. I don't recall. 15 15 the period of August of 2018. In fact, I would A. 16 Q. Did you ever submit what -- these one 16 have much more of the cell phone use after August 17 2018. 17 or more phones to a professional forensic company 18 for recovery? 18 Q. How is it possible that you had an MSN 19 A. I don't recall. 19 messenger account without having an e-mail Q. Did your Nevada attorneys assist you 20 address? 20 21 in attempting to get any data recovery from this 21 MR. GAVENMAN: Objection to form, 22 device or devices? foundation. 22 23 A. I don't recall. 23 A. Well, I only know when I have a cell 24 Q. Well, what do you recall about the 24 phone, then there is a cell phone number so that 25 recovery efforts for the data on the phones? 25 would be MSN, this function that I can use. I Case 22e500130-Dood50231KPFiledd3/119/02/113722113756g888 dPage 28 of
don't know that MSN is having any connection with 1 electronic copy of the original complaint filed in
e-mail. Nevada by you against Mr. Cheng on August 9, 2018.
We can scroll through it.
I don't recall.
in English or as translated before it was filed?
Q. Can you recall anybody who has ever A. Asimple translation, yes, someone had
helped you set up a cell phone? 7 briefly translated that for me.
I don't recall. A. Q. Who translated it?
I cannot recall. A. Yes.
A. Q. Were they affiliated with the Nevada
11 11 law firm, who translated it? 12 that iPhone? I don't know.
A. I don't know. A. 13 Q. How did you make the acquaintance of
14 14 this translator? 15 correct? MR. GAVENMAN: Objection, form,
A. Yes. 16 foundation.
Q. Do you still have it in front of you A. Well, I don't know this translator.
18 or with you in the room? Q. Now, paragraph 101 on page 13 states,
A. No, it's in another room. 19 19 "Cheng does not know Guo personally." Q. OK. We have had a few breaks so far.
21 Did you speak with anybody during those breaks? 21 two of you had met back months before this A. No. 22 22 complaint was filed, correct?
23 A. You have misunderstood because what it
24 anybody during any of the breaks that we have had 24 says here, Cheng does not know Guo personally 25 today? 25 meant before, long before we met personally, long
No. A. 1 before that he accused me of being rapist and
Q. Did you read the Nevada complaint 2 killers, I had to -- this millions and millions of before it was filed? 3 dollars of deal with Xi Jinping and betraying the
And actually strike that. I'm 1.4 billion of Chinese people, we did not know
going to upload a document. each other.
TECHNICIAN: Make sure you hit -- maliciously insulted me, threatening me, harming
MR. WOLMAN: I did. 8 me and before we met each other, we -- did he not
9 9 know me.
that. Q. I am sorry, when did my client call
MR. WOLMAN: The progress bar is not 11 you a rapist?
moving for some reason. A. Let me see, he started to have his
13 13 personal employee Marco in March and then started
14 14 out from April, May and June, all the way to document upload. ો રે 15 August, they started to maliciously viciously
16 16 attacking me verbally and him, himself and his Zoom. Can you use that? 17 17 personal employee, Marco, and kept calling me on
18 their platform that I was the rapist, I was, you
moment, please. 19 know, a peasant, I was a liar, I was whatever and
20 20 he -- they were making such threat to me and the 21 displaying the document on the screen. 21 safe -- threatening my safety and my family's
22 22 safety and we were constantly living in -- under
23 23 this kind of a threat and fear.
24 Q. Move to strike, not responsive. Case 22:5001:30 - DoOSIOZ31KPFileDd3/119/02/113756086113:56:18 0 0 f
2 was Ria Ma who was actually suing me for that.
employee, Marco, and all the time that on -- 3
4 saying that on Freedom China or Twitter, calling 5 me that liar. But I cannot recall exactly when forward right after I had made the broadcasting, 5 the whistleblower broadcasting in 2017, and then 6 that Cheng Shuiyan have called me that, and he and 6 on the same day, the notice from the Interpol had 7 his personal employee definitely did call me that 7 been issued for me, for me, my person, and then 8 starting from May or -- they did. 8 after that, this case was brought up.
10 10 case, I have not seen Ria Ma or the documents or 11 finished, sorry, Counsel. 11 the information was brought forward by the police
12 12 in mainland China. Ria Ma had never appeared or
(Simultaneous crosstalk) 13 never shown in any way.
15 translated. 15 fabricated case and brought forward by the Chinese
16 16 Communist Party police and that is why Cheng that translated. He is going to respond. 17 17 Shuiyan was so very familiar with this case.
MR. WOLMAN: He is not responding to But Ria Ma has never appeared and
anything. 19 in fact, we have been trying to look for her and MR. GAVENMAN: He most certainly is. 20 20 trying to get her to be the witness for this case
21 21 but she has never shown.
is filibustering. Q. That case is still ongoing, correct?
23 A. Yes. We -- I should say that we are
24 that you must let me translate that. And so -- 25 and because I have answered your question. 24 in the middle of looking for Ria Ma and we have 25 been looking for her for many months.
By the end of March and in June Q. To be clear, has anybody else accused and May and April, his lawyer, from Yingnan had you of sexual assault? 3 been -- had been calling and telling me that Cheng THE INTERPRETER: Sorry, I hear two
4 Shuiyan had been already accusing me of being a voices just now.
spy, a rapist and all that.
6 Ria Ma accused you of sexual assault?
7 privately told me that Cheng Shuiyan personally 7 A. No. 8 privately calling me rapist and liar and then also 8
9 like threatening and just, you know, in fact, it's の Q. As to -- there is no question posed. 10 on social media as well. 10 There is no question posed.
11 A. That is -- that is why the -- I need
12 make the allegation of me being a rapist openly. In 12 to sue Cheng Shuiyan because why would he know 13 fact, he also said that I was a rapist and I needed 13 that there was such a case, and then for bringing 14 to be deported and he tweeted that, too. 14 forward this case and then brought up this case is
And on the Twitter, he claimed 15 completely full of malice and vicious -- 16 that he had written to DOJ and his personal 16 viciousness and then trying to insult me, trying 17 employee, Marco, also written to the DOJ that I 17 to frame me and then it was trying to threaten me 18 was a rapist and needed to be deported, and so the 18 and ruin me. 19 Chinese government can, you know, just take care Q. And none of those allegations appear
20 of me and it was all done privately and openly as 20 though in Exhibit 3, do they? 21 well. MR. GAVENMAN: Objection, form.
23 door, were you sued for sexual assault? 23 emphasize to you -- that is why I need to clarify
Yes. A. 24 with you when you're talking about Exhibit 3, you
Case 22:5007:30 - DoO5I6231KPFiled@3/119/02/129122113:56:1860 dPage 30 of
understand English, I cannot read English. 115 that in March, Cheng Shuiyan met with someone from
Well, that is, that is why that I mainland China and he was actually a Mongolian
need to tell you that, because a lot of the 3 police. evidence that had not been appeared on this, in
this complaint and also that had not been brought 5 with this person and given hundred million -- 6 forward in the case of Nevada's lawsuit and that millions of dollars by this person and just so
7 is exactly why that they have -- there were two 7 that he can defame me and insult me. 8 lethal fatal made for that case and as a result, 8
we lost that lawsuit. d 9 and told by Lude and these are fact, factual as
10 10 just a piece of steel metal, and the only person 11 and that's Wang Ding Gang, and also Marco, who was 11 who would think that I am the enemy and I am a bad 12 the personal employee of Cheng Shuiyan, they made 12 person is the Chinese Communist Party. they are 13 this defamation insult of me and that was because 13 the only people who would consider me as enemy or 14 they were instructed and told by Cheng Shuiyan. 14 people working with them would consider me an 15 And so Cheng Shuiyan would need to be responsible 15 enemy. 16 for all the attacks and the insult and defamed So I can tell you I know that
17 remarks that they have made of me, and that has 17 that Cheng Shuiyan was very wealthy, but the thing 18 not been included in this case as the evidence. 18 is that the money that he got came from defrauding
19 19 people in China and being defrauding his business 20 information including in the cell phone and being 20 partner in China and coming from ill-gotten means. 21 lost and all that, I had not been included in any Q. And this information you got from a
22 of this complaint. And that is why that we have 22 person named Lude who was losing his job, correct? 23 lost it. And why that we have used a new lawyer MR. GAVENMAN: Objection to form.
24 and to open this case again. A. OK. So Lude did not lose his job.
25 25 Lude gave up his job because he did not want to be
that we have only -- I have only 15,000 of the conspired with the CCP. damage from him. It is a very low amount.
with Cheng Shuiyan, his life is even better. He
such a low amount is because it was only to try to was doing so much better with his anti-Chinese 5 stop him, stop him from making -- continue of 5 Communist Party activities. 6 making malicious insult and vicious rumor that is 7 very destructive to me and my family and also And also I must clarify, the
information did not come from Lude. As I stated,
8 spreading all this deception online about me and 8 the information come from Cheng Shuiyan -- the 9 created by him and his personal employee, Marco, 10 and proven by his conversations together with 9 lawyer from -- the Yingnan lawyer who is also the 10 Mongolian police, the intelligence police, and 11 Lude. 11 also that the -- to the Mongolian police
12 12 interviews of those people that who had been 13 into that complaint made to the Nevada case and that 13 disappeared, who had been arrested after they were 14 is why that we are pursuing that. 14 supportive of me and they were arrested by those
15 15 police, it come from those people as a source. 16 opportunity that we can provide more fact to the 16 Not from Lude. 17 judge and then for this case and so that we can Q. And other than Lude, you don't have
18 know that Cheng Shuiyan was in cohort with the CCP 18 the names today remembering any of these other 19 and conspired with them and spreading destructive 19 sources, do you? 20 insult of me and creating malicious rumors about A. If you wish to search for those names
21 me that is very destructive. 21 and, you know, if you have time, those names were Q. Do you have any -- excuse me, my turn. 22 22 online and you can actually find them.
23 Can you find them?
Q. 24 that my client is working with the CCP? I can try.
A.
Case 22:5007:30 - DoO5I6231KPFiled@3/10/02/254Enteried003/113:56:161 dPage 31 of
disclosures? repeat the interpreting?
MR. WOLMAN: Yes.
A. I borrowed from them. A. I cannot guarantee but I will try. Q. When do you think you can get us that Q. Is there an agreement memorializing
5 this borrowing?
No. A.
cannot promise. So I cannot tell you what -- Q. Do you have to pay them back?
when. MR. GAVENMAN: On advice of counsel, 9 Mr. Guo declines to respond to the question Q. Now, if you wanted to, you could have ರ 10 any of your legal pleadings translated for you, invoking his rights under the Fifth
Amendment of the U.S. Constitution. A. You mean by whom? Q. How much did you borrow?
Q. Did you have a certified translator 13 14 translate any legal pleading for you? Mr. Guo declines to respond to the question
A. Our lawyer was doing a fine job. invoking his rights under the Fifth
Q. How did you know your lawyer was doing Amendment of the U.S. Constitution.
17 a find job only now to find out there was Q. Was there a term of interest in this
18 information not included? 18 borrowing arrangement? A. So my -- what I meant was that usually MR. GAVENMAN: Objection to form.
20 lawyer would do a good job. It's just of course Foundation
21 that lawyer, that particular lawyer did not do a Yes. A.
22 good job. But usually lawyers can be relied upon. O. How much was the rate of interest?
Q. If you wanted to, you could have MR. GAVENMAN: On advice of counsel,
24 anything translated, correct? Mr. Guo declines to answer the question
Of course.
Q. Who paid for the litigation in Nevada? 1 1 Amendment of the U.S. Constitution.
Golden Spring.
Why?
that.
5 Mr. Cheng in Nevada, would Golden Spring New York of Mr. Guo's counsel, Mr. Guo declines to റ 6 have been entitled to any portion of that respond to the question invoking his rights 6
under the Fifth Amendment of the U.S. recovery? Constitution. MR. GAVENMAN: On advice of counsel,
MR. WOLMAN: Jeff, that's not an Mr. Guo declines to respond to the question
asset-related question. That is a invoking his rights under the Fifth
11 Amendment of the U.S. Constitution.
MR. GAVENMAN: We are invoking the Q. Have you borrowed from Golden Spring
Fifth. We have already been through this. 13 13 New York to finance any other litigation? We had 20 questions about why they pay for MR. GAVENMAN: On advice of counsel,
stuff. I don't know why you would think Mr. Guo declines to respond to the question
there would be a different answer here. invoking his rights under the Fifth
THE WITNESS: Counsel, I just need to Amendment of the U.S. Constitution.
go to close my window because the window is Q. Subsequent to your disappointment with
19 19 the prior Nevada law firm, have you done anything wind. So I need to close the window. Is it 20 20 to ensure that all documents in your litigation all right if I go to do that? 21 21 with Mr. Cheng are translated for you? 22 A. No.
Q. Did you ask Golden Spring to pay for 23
24 the Nevada litigation?
THE INTERPRETER: Counsel, may I take out document number 003.
Case 22:5001:30 - DoOSIOZ31KPFileDd3/119/02/113722113:56:16:2 dPage 32 of
4. And the document is on the screen.
initial disclosures filed by -- served by your
attorney in this case.
Q. Mr. Guo, I will represent that this is
the complaint and jury demand in this case.
translated?
you?
emphasize again, like this is an English document,
9 and you know, if you ask me any of the English 10 simultaneous interpretation of this document for 10 documents just posted in front of me on the screen 11 and to scroll down and let me see, I really cannot 11 me, a brief interpretation, but I do not recall 12 there was translation. 12 be sure that whether I have seen it or not or 123
13 translated the document or not. I really cannot
document that starts with 004. 14 be sure.
16 the document in front of me and let me really read and the document is on the screen.
17 in detail and try to remember, perhaps I can. But
18 just post in front of me scrolling, I just cannot be
19 sure.
21 to the complaint filed by Mr. Gavenman in this know I'm jumping around Juliet, sorry.
TECHNICIAN: No problem at all. 22 case.
24 for you? Exhibit 7 is on the screen.
A. Yes.
document, which was Exhibit 4, fully translated,
how were you able to assist in advising your
company whether or not to admit or deny certain
facts?
Q. This is a -- the document is a 24-page
reveal any attorney/client communications in document that is a your responses to our second
this answer. To the extent you can answer revised first set of requests for production.
without revealing them, you are free do so.
10 it, you will see there are over a 100 document 11 requests, of these numbered, many of which have 11 that you showed me previously, I actually cannot 12 be sure whether there were any words of 12 since been omitted. 13 translation. There may have, there may not have.
14 version of that, of any document with over 100 14 I just cannot be sure.
15 requests?
16 mean, that -- I may have seen it but I may not A. Yes, I recall.
17 have either.
Q.
18 you?
19 just wouldn't know for sure. That I cannot recall.
A. Q. OK. Now let's go to number 005. Q. So then let's go to 008.
been marked as Exhibit 6 and is displaying
the document on the screen.
Case 22e500130-Dood50231KPFiledd3/119/02/113722113756g863 dPage 33 of
Q. These are your Answers to the Revised Let's not go into medical records. There
First Set of Interrogatories. Why don't we scroll
was a request for that, we objected to it
and moved for a protective order on medical
boarder.
I must clarify, right, I mean, I cannot recall --
out your client doesn't know where he was 8 I cannot be sure whether there are translation -- 8 last week to sign this. 9 meaning a written translation document for me. 9
10 what his care is or isn't is really not
11 these documents was provided by my counsel to me. relevant. He doesn't remember where it was.
Q. Do you understand that you signed that 12 It's really where it should begin and end.
A. Of course. 14 14 question?
Q. Are you certain that you understood THE INTERPRETER: Counsel, I don't
16 the translations of your answers as appearing in believe I finished the interpreting of that
17 this document? question. Can you repeat that question for
Yes.
me.
19 Q. Sure. Has any physician diagnosed you
20 document? 20 with a memory condition? A. I cannot recall. 21 No.
A. This was last week, correct?
0. Q. Turning back to the last exhibit which
I cannot recall.
A. 23 was 00 -- which is Kwok 7, what did you do to Q. Do you see the date, March 24, 2021? 24 24 search for responsive documents?
25 A. Our lawyers have made the search for
March 24, right? 1 documents.
Q.
Q. Where do you store your documents?
In that case, it's March 24.
A. I did not store or kept any document.
Q. And you don't remember where you were Q. Did you provide your lawyers with any
of your phones or other computer devices?
I really don't recall.
I don't have computer. A.
Q. Earlier in this deposition, I asked 7
you if you had any medical conditions that would 8 8 using to stream this deposition? 9 prevent you from answering the questions d A. Acell phone. 10 accurately. Q. Is that a cell phone different from
Do you have some sort of medical 11 the one you showed us before? 12 condition that affects your memory? 12
A. I recall that.
14 mind if I clarify the term with the witness?
15 recall where you were last week to sign this MR. WOLMAN: Sure.
16 document? A. So in front much me, it is a video
A. I don't know. 17 playing device.
18 Q. What kind of device is it?
19 neurologist? A. I don't understand. Because you see
A. No. 20 20 they were in English writing -- they -- there was
21 21 an English writing, so I don't really know.
Q. Is it a computer?
23 A. No, it is an image video device or
25 remember where the document was signed. 24 something called image pick-up device, something 25 like that.
Case 22:5007:30 - DoO5I6231KPFiled@3/119/02/113722113:56:164 dPage 34 of
Q. How is it connected to the internet? lawsuit in Nevada, we were full of good faith,
A. Because it is a photo imaging device, only asking for a very minor amount, 15,000
so that it can be connected with the internet. dollars. The purpose of it merely to stop him
Q. Is it connected through some form of attacking us, stop him spreading malicious vicious
rumor that has cost severe destruction to myself
A. It has wifi and it has cabling wire and my family.
Q. And it doesn't connect -- does it 8 family's mind because imagine that they were told
connect in any way to a computer? 9 that they will be deported back into China, in the
A. I don't really know because it has a 10 hand -- put in the hand of the Chinese Communist 11 box. It's called a live broadcasting box because 11 Party and put into prison by the Chinese Communist 12 I broadcast with myself anywhere. So that's why 12 Party and then Cheng Shuiyan and his personal 13 this is a portable device and it has a live 13 employee, Marco, came right to the Department of 14 broadcasting box. So I don't know whether it's 14 Justice and request us to be deported. And that 15 connecting -- can be connected with computer or 15 is the kind of fear and that kind of scary 16 not. 16 accusation that is spread on us. Q. Where do you store your records?
MR. GAVENMAN: Objection to form. 18 18 vicious intention, and we, in return, we were just A. Well, I don't have anywhere that I can 19 19 like asking for 15,000 of the damage just to stop 20 keep any records because unlike Cheng Shuiyan, 20 him for spreading that kind of a rumor about us 21 every day, I was trying to run away from, escape 21 and in good faith. 22 from the persecution coming from the CCP, and I am Q. One -- please, let sir, sir. What do
23 not as wealthy as Cheng Shuiyan who has hotel and 23 you mean by "we"? 24 who has properties, you know, and every day, I'm 24
25 just running around. And I don't really have any 25 interpreter who interpreted it into "we," but I
place that I can keep that record. only say "I."
Q. When you say you're not as wealthy -- 2
excuse me, when you say you're not as wealthy as 3 actually asked for monies in excess of 50,000 dollars on the face of the second amended
my client, how do you know that?
complaint?
any piece of this answer that regards your
A. Yes, I know that. assets or not assets, Mr. Kwok, on advice of 7
counsel, you should decline to respond to 8 punitive damages?
the question and invoking your right to the Fifth Amendment to the U.S. Constitution. 10 A. Yes, I know that. But then you see 11 10 the thing is, in the past, right, he has -- not in 11 the past. I know that because he has caused me so
Mr. Cheng's assets, you can answer. 12 12 much damage and he has tens of -- several tens of
13 13 a million dollar. 14 hotel in Las Vegas and Lude also said that he has I know that. And then he -- what
15 other profit shares, and based on the Mongolian 15 he did cost me so much of destruction, cost me so 16 policeman who had to interview a lot of the 16 much threat, and then cost me so much fear and 17 people, those people have told me that Cheng 17 then full of this -- because he have made those 18 Shuiyan has a lot of properties probably in 18 malicious, defamed accusation allegation of me, 19 Mongolia as well. 19 calling me rapist, calling me killer, calling me
20 20 criminal, and so when I was asking him of that 21 Cheng Shuiyan is reported to have a billion 21 punitive damage, it is really full of good faith 22 dollars at least of the asset. Wealthy enough to 22 and he is well capable of paying it. 23 send me to prison in China and have me deported And also you see he and his
24 into a China to be imprisoned there. 24 personal employee, Marco, wrote to the Department
Case 22e500130-Dood50231KPFiledd3/119/02/113722113756g865 dPage 35 of Transcript of Howan Kwok Conducted on April 1, 2021 34 (133 to 136)
stated I was wanted in the Chinese -- in China by ો રેર to be made responsible for his employee, his
the Chinese government. personal employee, Marco, who had kept on making
all this allegation about me and spreading
document that stated that I am a wanted person in 4 malicious rumors and gossipped about me. He have 5 China by the Chinese government. So where did 5 to be made to take that responsibility. 6 they get these government -- they fabricated this 6
7 document and all that is because they had the 7
8 purpose of deporting me into China back into the 8 question?
9 hand of the Chinese government and then wanting me
11 next question is pending.
12 actually paid and that is actually enough to be 12 then you can continue to respond. 13 paid for by just tens of thousands or that kind of Q. You mentioned a letter at Department
14 a punitive damage? 14 of Justice from my client. Why have you not
Q. Thank you. 15 produced it?
16 A. Well, the thing is that document was
17 17 written by Cheng Shuiyan and his personal 18 me, excuse me, there is no question. Excuse me. 18 employee, Marco, to DOJ, he, himself. They openly 19 Excuse me. Excuse me. Excuse me. There was no 19 talked about it, tweet about it online, over the 20 question pending. 20 internet.
22 22 who need to go and get that document and provide 23 finished my answer. 23 to you. That is their document. And that has
Well, you see the thing is, all 24 already been sent to DOJ. How can I get such a 25 the things that he has said have been forwarded 25 document? How can I get it from the DOJ?
1 and have been transmitted in mainland China and 1
forwarded to millions and tens of millions and
have openly talked about it on Google, online, and
perhaps like hundreds of millions of the viewers. it is constantly harassing me with that kind of a
And then those messages were statement and the damage they have caused is
constantly calling me Guo rapist and Guo criminal really, you know, can't be estimated. And that is
6 and stating that the, in America, Department of why the damage has to be sought.
7 Justice is going to deport me back into China and 7
8 then calling me peasant, using words that -- as document, correct? You don't -- don't --
9 filthy as anything that can be and those words and 9
10 those messages is going to accompany me throughout MR. WOLMAN: Counsel, instruct your
11 life. It's never going to be erased, never able 11 client to wait for a question. He gives an
answer. I get to now ask another question.
This is how it works. 14 my kindness that only at the beginning, I had a MR. GAVENMAN: Jay, you didn't follow
15 dinner with him, and also during that time, I was any instructions when it was your client
16 very kind, I was very nice and return. Then he doing unbelievable things. He is giving the
17 treated me with such malice and turning white to answer, complete answers. You have to let
18 black and then calling me all kind of names. Of him complete the answer.
19 course, I'm going to pursue him. I would never MR. WOLMAN: He is filibustering.
20 give up in pursuing him with the damage. MR. GAVENMAN: You are asking
21 questions about this document, why it wasn't
Q. Hold on, hold on, it's not responsive produced and he is giving you an answer.
23 to my question. You are filibustering again. Q. Do you have the document?
MR. GAVENMAN: It's not a filibuster. 24 A. So I haven't completed my previous Case 22:5007:30 - DoO5I6231KPFiled@3/119/02/129122113:56:166 dPage 36 of
Q. Do you have the document, yes or no?
MR. GAVENMAN: You need to allow him with any of the documents that were used to
to complete his answers. That's fundamental 3 respond to the requests for production in this
case?
complete his answer. You asked why not. 5 MR. GAVENMAN: Objection to form.
There is a pending question. He has to be 6 A. What documents?
MR. WOLMAN: It was nonresponsive. produced documents to us in this case?
9 Of course I know.
A.
10 Q. And do you know what those documents
and its whereabouts. 11 11 were?
12 A. Of course I know.
question then. Q. Excellent. So did you give any of
14 14 them to him? 15 that document? MR. GAVENMAN: Objection to form.
16 Of course. A.
17 previous question. Q. Which documents did you give to him?
Q. No, I've withdrawn that. 18 MR. GAVENMAN: Objection to form.
question. mind if I ask the witness to clarify because
21 I can't hear clearly.
22 MR. WOLMAN: Sure.
do not have an answer to that question.
24 24 provided by our counsel which, in turn, provided 25 no explanation. Yes or no. Do you have it? 25 by me to my counsel.
MR. GAVENMAN: Objection to form. MR. WOLMAN: Move to strike as However, however, I don't have
2 the document that was written by Marco or Cheng
nonresponsive.
(Simultaneous crosstalk) Shuiyan to DOJ and that is why I want to actually ask them to get that document.
that were produced in the response to the request
don't know what I'm answering, counsel.
understand what yes and no mean in Mandarin.
interrogatory answers.
10 question and then I am speaking in Chinese and you 10 your counsel for production? 11 don't know what I am saying. You must allow me to A. Yes, I provided those documents to my
12 answer your question. 12 counsel.
13 Q. Which ones?
14 and my client's name. I want to know do you have A. Anything that you can see were mostly
15 the letter, period. 15 provided by me.
16 Q. Excellent.
Move to strike. 17 How did you get them to him?
Marco and his boss have them. A. 18 MR. GAVENMAN: Objection to form.
Do you have it? Q.
I don't have.
A. 20 would be it. Have you ever had it?
Q. Q. You handed them to Mr. Gavenman?
No.
A. A. I mean that I gave them to the lawyer
Have you ever seen it? Q. 23 in Golden Spring. No.
A. Q. Where did you find these documents to
Q. Thank you, that was easy enough. 25 25 give to the Golden Spring lawyer?
Case 22:5007:30 - DoOSIOZ31KPFileDd3/119/02/113722113:56:167 dPage 37 of
1 to not reveal anything about what you heard talking about.
in an attorney/client communication about
Any of them.
what your attorneys were doing separately
from you.
at Golden Spring and tell me where it came from.
9 that you can say such a general term as any of did.
10 them. You know. I don't think this is something A. My answer is that I don't recall.
11 that the professional lawyer should say. Q. Did you look for any documents to
12 12 respond in this case?
A. Of course.
14 And where did you look? Q.
to the witness? ] ર I don't recall.
A. MR. WOLMAN: Strike that.
17 17 reask you those very same questions?
MR. GAVENMAN: Objection to form. please repeat my question.
asking the court reporter to repeat the 20 understand really what you mean.
22 22 to -- or to look for in response to the request
23 23 for production, just appear by magic? and then you will reinterpret.
attorney/client communications, please don't
to pick which document.
reveal those communications. To the extent
you know anything outside of that, you're there are a thousand pages of the documents and so
free to answer. I should know that to pick which one and to talk 5
about it, where it came from. 6 the conversation between myself and my counsel, I
cannot talk about here. I cannot talk about here. 8 says any of the documents, you know. In my life, 8
9 I never have anything that is any of the documents 9 those documents, I just don't remember. I don't 10 such a general term. It's either right or wrong. 10 recall.
12 thousands of pages that you assembled to give to 12 today if you were being asked? 13 the lawyer at Golden Spring? MR. GAVENMAN: Objection to form.
A. I don't know.
Q. ો ર 15 right, the communication between Marco and Cheng 16 this lawyer? 16 Shuiyan, for example, this kind of evidence, Marco MR. GAVENMAN: Objection to form. 17 17 is Cheng Shuiyan's personal employee and they
18 18 said, they claimed that they wrote to the DOJ. 19 there are so many times, I don't know exactly 19 And to deport me. And then calling me online 20 which specific time that you are talking about. 20 about that I was a liar and I was a rapist and so
21 21 on and so forth, and all of that, they 22 request for production of documents propounded on 22 acknowledged and they openly treated that. 23 you in this case, tell me what you did to search 23
24 for documents to produce.
ટર્ર 24 to produce that, and that's one way. And they 25 make phone call. For example, I make phone call
to the people that they have talked to in mainland 1 dollars from him. And that had already been very China. I make phone call to Lude who they had
clear evidence that we -- we act in good faith. And
talked to about that -- about what they want him of course, the only thing here is we only want to
tell the truth.
So all of that -- and then I call them 5 Q. Were any of the documents in this case
and got those answers, and so that is a way to 6 provided to you by your attorneys?
answered about four times.
later on, you know, Marco and Cheng Shuiyan, they 9 MR. WOLMAN: Asked yes, answered no. 10 talked about all of things that they have done and MR. GAVENMAN: He is answering the
11 they tweeted it online and you search online and question. It's part of the responsive
12 you get all this information online and then later documents -- I don't want a speaking
13 on, that, you know, after -- at the Nevada case, objection, but these are -- that's his
14 he disappeared, Marco disappeared. He was a answer and there is a reason that's his
15 personal employee of Cheng Shuiyan. ાં ર answer.
16 MR. WOLMAN: Did any of the documents
17 responsible for whatever he did or said anyway. you produced come from him?
18 So all of that was actually appeared online MR. GAVENMAN: He's clearly answered
19 because they have many tweeters online and they that question and I'm not being deposed so
20 have tweet it out there openly. That is a way to you can ask questions, he is answering them
and we can move on.
23 documents responsive to the requests? doesn't seem to remember where documents
MR. GAVENMAN: Objection to form. 24 were produced or what he produced or where
A. Well, for example, when we -- when you they came from. So I'm asking you.
see that, for example, Cheng Shuiyan reported that
he have a billion of dollar of asset and he 2 here today. So you can ask a questions --
purported that he is person, but for all these MR. WOLMAN: Actually, right now, I'm
kind of purported claim, of course I can call
people in China trying to ascertain his, the words 5
of his claim. So that is one way to search.
and place for a meet and confer while he is and Marco, so Marco is his personal employee 8 being deposed. And I know you know that. 9 and he need to be -- Cheng Shuiyan need to be 9 It's not meet and confer time now. So 10 responsible for whatever Marco has said and done 10 continue your deposition we can meet and 11 and so he was his boss. 11 confer afterwards if you like to.
13 knowledge and that is the things that we know. 13 would be useful for us to confer as to
14 14 whether or not he actually conducted an 15 Nevada, we brought the case in good faith. The 15 appropriate search. And then maybe once we 16 proof, the evidence of that is we only claim for a 16 have established that, well, he didn't 17 very small amount and we did not claim for 17 provide you any documents, we can go with 18 millions of dollars even though that he has -- he 18 that. 19 claimed that himself, he had that billion dollars But if you want, we can keep going,
20 of this account of assets. 20 sure. But I was trying to make this easier
21 21 for you. 22 the people in China, subsequently a lot of people 22
23 were made disappeared and the thing is that he had 23 care and concern. As always. Please 24 caused me all this destruction and all this kind of 24 continue. 25 a harm, we did not seek millions and millions of 25 MR. WOLMAN: Not a problem.
Case 22:5007:30 - DoO5I6231KPFileDd3/119/2254 Enteried:00118822113:569 dPage 39 of
THE INTERPRETER: Is there a too much damage, too much of a harm that he has
question, counsel? caused me.
MR. GAVENMAN: There is not.
Q. You said Mr. Cheng caused you a lot of to him, it's only a simple word. He called me a
harm. How do you value that harm? rapist. But the damage it caused me, how can I
A. Well, so it is going to be a very, account for that? How can anyone just fathom the
very long story. You need to have some damage that it is?
preparation. It's going to be a long story. 8
Q. No, I'm asking you how you value the and then calculating it. I'm in the middle of
1 () harm. 10 doing it.
12 preparing some kind of premises to how to gauge 12 your claim against Jonathan Ho valued at 5 13 the destruction and harm caused by Cheng Shuiyan. 13 million; your claim against Jianbin Yuan at 5 14 I have been calling people in Japan, Hong Kong 14 million; your claim against Liang for 100 million; 15 PRC, U.S. and some of the partners before. 15 your claim against Baotang for 1 million; your
16 16 claim against Eliang Xia for 5 million; your claim 17 the moment, they were under threat and they were 17 against Xianmin Xiong for 100 million? 18 not -- they did not want to, you know, be the THE INTERPRETER: Counsel, I will
19 witness and tell how much threat and how much 19 probably need you to repeat those names. 20 damage, and they know that Cheng Shuiyan and MR. WOLMAN: Sure.
21 Marco, his personal employee, have caused me MR. GAVENMAN: I want to caution, to
22 because they were being sort of under threat and the extent any of that information, any of
23 also they know from the open allegation that made your understanding about why that was put in
24 by Cheng Shuiyan and his personal employee, Marco, those various complaints or how the value
25 that I will be deported by the Department of was done that came from counsel, you should
Justice to mainland China and I will be deported not reveal those communications. 2 to mainland China and they have made that kind of 2
allegation on Twitter, on Geteer, talking about
4 that I will be deported -- not only that I will be communications, you are free to do so.
deported. They keep on saying that I will be shot 5
6 to death by the Chinese government. And they keep 6 million, the first name is Jonathan? repeating that so that cause a lot of fear by a
lot of the people that I have worked with in the
Jonathan Ho.
10 10 person, right? 11 and he cost me a lot of this kind of a damage and MR. WOLMAN: Yes.
12 it is unaccountable and it would be these, I think THE INTERPRETER: And that's 5
13 if I am gauging such kind of a value, I would say 13 million? 14 several tens of millions at least. MR. WOLMAN: Yes.
Q. You said he cost you a consultant job THE INTERPRETER: Then 100 million
16 and damages. What consultant job and what damage? 16 Liang, someone Liang, and 1 million, A. I cannot answer them here for you. 17 17 Baotang, Baotang, 5 million Xia -- Q. Why not? 18 18 something.
A. Because at this point, I just cannot 19 MR. WOLMAN: Y-E-L-I-A-N-G, X-I-A. 20 remember them. THE INTERPRETER: And then 100
Q. But somehow -- you can't remember jobs 21 million, Xiong something? The last name. 22 that were valued had a worth of tens of millions MR. WOLMAN: 100 million was
23 of dollars? 23 X-I-A-N-M-I-N, X-I-O-N-G. MR. GAVENMAN: Objection to form.
25 A. A. It's because -- it's because -- well, MR. GAVENMAN: One moment please
25 recall my instruction about the attorney/
Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 40 of ¡¡¢£¤
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Case 22:5007:30 - DoO5I6231KPFiled@3/119/02/11375608113722113:56:13 dPage 43 of
suggested and I don't have to tell you that
my lawyer suggested it.
MR. GAVENMAN: -- and say the me about any communications you actually had with
attorney/client communications. And he is 5 your lawyers, why did you decide to pull the
free to do that. 6 trigger and have four cases filed on the same day?
this answer would reveal any amount of any reveal attorney/client communications.
legal strategy between you and your counsel,
10 you cannot talk about that portion.
11 that came from an attorney/client MR. WOLMAN: That is not correct. He
12 communications, any understanding you had 12
13 that came from it. -- MR. GAVENMAN: That's my instruction
14 to my client. It's a question for the
15 an understanding. judge.
17 wanted to do something without telling need to learn about privilege, Jeff. That's
18 me what was discussed. Because he could not how it works.
19 think, oh, it's a great idea to do what MR. GAVENMAN: Jay, very good, thank
20 my lawyer told me without telling me you for your help in being so wonderful as
always.
23 along those lines. that question if it is about
MR. WOLMAN: No, you didn't. 24 attorney/client privileged information
MR. GAVENMAN: If you answer the and strategy that came from his
attorney.
separately, he is free to do so.
Answer the question. Q. 5 assuming there, some of that portion, at 5 A. Well, there is no other reason really. least some of that answer is wrapped up in 6 It's just that we have looked at all the cases,
attorney/client privilege. 7 consolidate, in a consolidated manner, we look at
all of that, and then the counsel recommended 9 not, he is free to answer it. 9 that, you know, that to put those four cases on
10 10 the same day and that is all. 11 attorney discussions about what certain Q. I'm a little confused because these
12 things would happen, why certain things 12 were filed, two in New York, one in New Jersey, 13 would happen certain ways, those are 13 and one in Virginia. 14 privileged communication that he can't How is this all one counsel
15 reveal. 15 having the idea to put them all in the same day?
MR. WOLMAN: He can still say I I don't know. A.
17 decided to do something because of "X" even 17
18 if it was an idea his attorney told him.
MR. GAVENMAN: Well, if it was a 18 your behalf? Of course.
A. 20 privileged communication and privileged Well, I'm actually quite curious,
21 understanding -- 21 counsel, why are you banging on this question
22 22 about one day filing cases for one day. I mean, 23 privileged goes to communications between 23 it's such a strange and curious question. 24 you and your lawyer. Privilege does not go Why can't the cases be filed on Case 22:5001:30 - DoO5I6231KPFiled@3/119/02/129122113:56:184 dPage 44 of
is wrong?
It's really if I recall that correctly, 2 interrogatories in that case?
this is the first time I ever heard of this 3
interrogatory to what case?
actually don't remember these four cases were
questions in that case? 7 filed in one single day. And so that, you know, 7 A. I don't remember all of it. 8 if it were not you who keep on asking about this 8
9 question about these four cases all filed on the 9 in it, it says, quote, I will represent that this 10 same day, I would not have known there was such 10 is at Bates quote 3733, "Plaintiff responds that 11 four cases and they were all filed on the same 11 he is an entrepreneur without a salary or income." 12 day. I really had no idea. Is that statement accurate?
Q. What is your relationship with Eastern
14 Profit Corporation Limited? Mr. Guo declines to respond to the question
Mr. Guo declines to respond to the question 16 Amendment of the U.S. Constitution.
Amendment of the U.S. Constitution. 18 18 question?
A. Yes.
20 Q. Was that statement accurate on the
acknowledged that he was principle of 21 date it was made and filed being November 18,
that -- 22 2019?
MR. GAVENMAN: I understand. MR. GAVENMAN: On advice of counsel,
24 Mr. Guo declines to respond to the question
District of New York. invoking his rights under the Fifth
MR. GAVENMAN: I understand. Amendment of the U.S. Constitution.
Q. Are you refusing to answer?
A. Yes.
Q. Did you reach a settlement in the case
with Mr. Xianmin Xiong?
A. Yes. A. Well, first of all, I must tell you
How is our timing? Thave that the pronunciation of that name was wrong,
other obligations. right?
least another hour. 10 even to this date, that case was not entirely
MR. GAVENMAN: Fifty-nine minutes. 11 settled.
Q. You provided to us in your discovery Q. Are you aware that a stipulation of
13 responses your responses and objections to 13 discontinuance was filed on September 15, 2020? 14 interrogatories in a lawsuit against by you A. Well, that's only one of the cases and
15 against Xianmin Xiong, X-I-A-N-M-I-N, X-I-O-N-G. 15 there are other cases that were in connection with
16 16 Xianmin Xiong as well.
19 Xianmin Xiong, or perhaps it is the interpreter 18 prejudice, correct? A. That is not true. 20 did not interpret the name right. Q. Are you saying that the document filed
21 21 on New York State's court electronic system is 22 as Frank, also known as Xino, also known as 22 incorrect?
MR. GAVENMAN: Objection to form.
25 I know this case. A. Well, perhaps the document was not
25 wrong, but then there are so many other cases that
Case 22e500130-Dood50231KPFiledd3/119/0254Enteried0091137221137569615 dPage 45 of
were -- that has some connection with Xiong system for New York's courts between you and
Xianmin as well. Xianmin Xiong other than the one that was
dismissed by a stipulation?
pronounce that or anyone on his behalf make any 4 I don't know. A.
payment in exchange for that case being 5 Q. Who is Yanping Wang a/k/a Yvette Wang? discontinued with prejudice? 6 A. She is from Golden Spring.
Q. And what is her job at Golden Spring?
So she is the president. A.
with prejudice without any payment? Q. Do you know anything about her lawsuit
10 10 against Xianmin Xiong?
11 Yes. A.
strategy communicated between you and your 12 Q. What your role with respect to that
counsel, you're free to answer. 13 13 lawsuit, if any? A. Well, that was the strategy that I had 14 A. No.
15 together with my counsel. Q. Have you spoken with Ms. Wang
16 16 regarding this lawsuit? 17 million dollars. Do you not recall that? A. No.
A. Yes. 18 Q. I want to make sure I understand.
Q. How did it benefit you to dismiss that
20 case without getting a dime in recovery? 20 also known as Yvette Wang, is the president of MR. GAVENMAN: Objection to form. 21 21 Golden Spring that is financing your defense in
Objection to form and same caution. 22 this case and has otherwise paid the judgments to
A. Well, that is actually a strategy that 23 my client, but you have never discussed this case 24 we have arrived between myself and my counsel. 24 with her, correct?
25 MR. GAVENMAN: Object to form.
A. Yes.
have a treasurer?
A. Well, the whole matter has not been Of course there is.
A.
Q. Have you discussed this case with that
Q. What part of it is still ongoing since 6 treasurer?
No. A.
A. Well, I cannot just -- I cannot tell Q. What is the name of the treasurer of
9 you because that is the strategy that I and my 9 Golden Spring Limited? 10 counsel arrived at. I don't know.
A. Q. Is that counsel Mr. Steinberg?
One of them.
A. 12 identify as being an officer of Golden Spring?
Q. Have you filed any other lawsuits I don't know.
A. 14 against Xianmin Xiong or however you pronounce it?
A. Yes. 15 15 judgment against you by Mr. Cheng in the Nevada Where? In what court?
0. 16 case? New York.
A. A. Well, lawyers communication.
(). Q. Do you know the person -- who the
19 complaint? 19 person was at Golden Spring who initiated the wire I don't recall. A. 20 20 transfers to our firm?
Q. When did you file this new case I don't know.
A.
22 against Xianmin Xiong?
A. I don't recall. 23 Golden Spring to initiate wire transfers of funds? Q. Do you know if there is any reason why 24 I don't know.
A. 25 there is no case currently on the electronic Q. You produced to us some text messages
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Case 22:5007:30 - DoO5I6231KPFiled:03/119/02/113722113:56:18 7 dPage 47 of
I don't recall.
A. Q. I'm asking you, do you want to change
Q. Is anybody, other than you, authorized 2 any of your answers?
to deposit checks made payable to you? 3
I don't know. A. of these things that I just mentioned about,
5 right, and it's actually -- I remember when I
calendar year 2020? 6 answer you, I said that is May, but it actually
Of course. A. 7 started all in March, 2018, all the way through to
Q. Did you include this 12,000 dollar 8 August, and then I sue him in September of 2018. payment for judgment as income in that tax return? 9 9 So that would be the change I would like to make.
Mr. Guo declines to answer the question 11 Baosheng in Virginia, paragraph 107 of the
12 12 complaint in that matter states, "Guo acted on Amendment of the U.S. Constitution. 13 13 these false representations and relied on them
Q. Are you refusing to answer? 14 when he gave Baosheng 42,000 dollars in total." Yes.
16 16 source of the 42,000 dollars? 17 today -- now that you have had a day to think MR. WOLMAN: And before you make your
18 about it that you wish to change? speaking objection --
A. Yes. MR. GAVENMAN: No, it's on advice of
Q.
And what is that? counsel to respond to question --
22 and his employee relationship with Cheng Shuiyan this case, this case went to trial, so I'm
23 and they have sent out tweet messages, online asking -- so he obviously put forth evidence
24 messages, and for the time they send the message of that payment to Baosheng. So my question
25 and the content of the message and also the is -- that's already now out in the public
relationship -- and also that the message is sent and public record. So my question here is 2 between them to Wang Ding Gang via WhatsApp and 2 what was the source of that money?
3 also just the matter that the personnel from 4 4 Bejing visiting Cheng Shuiyan and gifting him 5 millions of U.S. dollars and so as to start his testify about that matter here today,
6 changing of the -- the turn of the event with me, Amendment of the U.S. Constitution.
7 all these matters, I should start from the 7 8 beginning to tell you that. Q. Are you refusing to answer?
ರ interpret everything that just happened.
10 Cheng Shuiyan of defaming me on Twitter, this Yes.
A. 11 platform, concerning about my family and calling 11
Q. 12 me rapist and calling me a hooligan, calling me 12 case? 13 low class, a peasant, and not even -- low class 13 Yes. A. 14 peasant and talking about me having a big deal 14 Q. Did you testify that you paid Baosheng 15 with Xi Jinping, all of that, I would also like to 15 Guo 42,000 dollars? 16 start to tell you that. A. Well, Baosheng Guo was 2011 the
17 17 partner of Cheng Shuiyan in this whole business of 18 tell you about the matter that Cheng Shuiyan 18 attacking me and the fact that he is one of the 19 talking about on Twitter in relation to writing to 19 persons who attacked me together with Cheng 20 the ministry -- minister of or department head of 20 Shuiyan the most. 21 DOJ and claiming that he is to -- they are going MR. WOLMAN: I'm asking the court
22 to deport me to China and telling that I was a reporter, move to strike as nonresponsive.
23 criminal and I was a wanted person, all these Q. Did you testify that you paid, you
24 matters, I would like to actually tell you about 24 paid Baosheng Guo 42,000 dollars?
Case 22e500130-Dood50231KPFiledd3/119/02/113722113756g868 dPage 48 of
Q. Did you write a check to Baosheng Guo 187
2 going to suspend the deposition at this
for the various amounts he requested? 3 point pending the issues regarding the
I don't recall. A. 4 claims of Fifth Amendment privilege. 4 Q. How did money go from you to the -- 5 THE WITNESS: Thank you very much. 5 how did 42,000 dollars go from you to Baosheng 6 (Time noted: 6:16 p.m.)
7 MR. GAVENMAN: On advice of counsel, 8 8 Mr. Guo declines to respond to the question HOWAN KWOK
Amendment of the U.S. Constitution.
Q. Are you refusing to answer? 11 before me this
A.
、2021. 13 Q. From whatever account or accounts that 13 14 you used to pay Baosheng Guo, how much money is in 14
16 MR. GAVENMAN: On advice of Mr. Guo's 16 17 counsel, Mr. Guo declines to respond to the 17 18 question invoking his rights under the Fifth 18 Amendment of the U.S. Constitution.
21 payments to Mr. Guo, Baosheng Guo? 21
I don't recall.
23 Q. Who would have records -- strike that. 23
25 introduced as evidence in the trial between you
INDEX: and Baosheng Guo?
EXAM BY: PAGE:
Q. Do you have control over those 3 H. Kwok
5 MR. GAVENMAN: Objection, objection 5 EXHIBIT INDEX:
PAGE: 7 A. I am not quite sure I understand what 7 Exhibit 1 Amended Notice of Deposition
you mean. 8 Exhibit 2 Defendant Wengui Guo's
9 Q. Do you or your attorneys have copies ் Verified Statement Pursuant to 10 of the exhibits introduced at the trial between 10 Local Civil Rule 26.1 11 you and Baosheng Guo? 11 Exhibit 3 document entitled "Complaint"
12 A. I actually don't quite understand what 12 Exhibit 4 Complaint and Jury Demand
13 you -- what your question means. I don't 13 Exhibit 5 Defendant Wengui Guo's Answer
Q. What is Broadcasting Board of 15 Exhibit 6 Defendant Wengui Guo's Initial 123
17 THE INTERPRETER: Counsel, is that a 17 Exhibit 7 Defendant Wengui Guo's
company or is that -- 18 Objections and Responses to
MR. WOLMAN: A company. 19 Plaintiff Logan Cheng's Second 20 THE INTERPRETER: It is a company? 20 Revised First Set of Requests
MR. WOLMAN: An entity. Yes. 21 for Production of Documents 22 A. I cannot understand exactly what this 22
24 23 means. I don't understand this question at all.
questions?
1 EXHIBIT INDEX:
PAGE:
)ss:
8 and New Jersey, do hereby certify:
12 such deposition is a true record of the 13 testimony given by such witness.
ાર related to any of the parties to this 16 action by blood or marriage and that I 17 am in no way interested in the outcome 18 of this matter.
21 April, 2021.
Case 22:5007:30 - DoOSIOZAK PFiled 03/11/02/22/2113:56:18 0 dPage 50 of 92
accounts 90:23, 94:12, 46:19, 48:10, A 96:20, 98:15, 49:15, 50:4, 50:24, 185:13 aaron accurate 101:20, 106:4, 67:12, 69:14, 35:6, 35:22, 72:23, 74:7, 110:11, 111:1, 6:22, 7:5, 35:23, 36:2, 111:2, 115:2, 75:16, 75:24, 66:12, 15:7, 36:7, 36:9, 115:8, 116:22, 76:12, 76:22, 74:6, 171:12, 36:10, 36:13, 122:11, 128:12, 90:1, 91:4, 171:20 36:16, 36:21, accurately 132:3, 133:12, 118:4, 119:8, 37:5 140:3, 145:18, 119:13, 119:23, 15:12, 126:10 ability 148:3, 148:14, 120:8, 120:14, accusation 5:17, 15:5, 153:7, 156:9, 130:7, 159:14, 131:16, 132:18 15:11, 34:12, 159:20, 161:20, 160:7, 161:9, accused 35:3 167:4, 168:20, 162:21, 163:3, 108:1, 112:1, able 169:6, 170:18, 169:15, 171:13, 112:6 17:11, 24:10, 173:23, 178:25, 171:23, 181:10, accusing 34:16, 37:3, 180:6, 182:24, 183:19, 185:7, 110:4 39:10, 39:13, 183:5, 183:6, 185:16 acknowledge 52:22, 53:1, 186:12 advise 5:5, 13:4 57:3, 82:11, adding 153:4 acknowledged 93:18, 122:3, 18:12 advising 144:22, 169:21 134:11, 137:4, address 122:3 acknowledging 137:7, 158:5, 8:10, 104:20 affects 41:13 158:10, 158:21, addresses 126:12 acquaintance 179:20 66:2 affiliated absolutely 107:13 addressing 31:18, 55:22, act 106:18, 154:2, 75:7 104:8, 107:10, 147:2 162:11 160:8, administer 155:10 abuse acted 4:16 affirm 86:25, 157:21, 180:4 183:12 5:14 admissibility accepting acting afield 5:8 30:7, 93:25 24:23, 39:17, admit 83:14 30:22, 31:6, action after 122:4 31:15, 74:19 15:22, 190:17 advice 21:14, 44:7, accompany active 53:14, 92:2, 12:7, 12:13, 134:10 14:7 12:19, 13:20, 92:3, 95:1, according activities 97:19, 24:18, 24:24, 104:16, 33:18, 178:16 91:25, 116:5 30:2, 30:8, 111:4, 111:8, account activity 30:23, 116:13, 145:13 30:18, 36:24, 36:25, 159:19 31:2, 31:7, afterward 57:11, 65:20, actual 31:11, 31:16, 87:11 65:23, 66:5, 114:23, 141:13 37:6, 37:11, afterwards 99:4, 104:7, actually 37:25, 38:6, 148:11 104:19, 146:20, 9:8, 34:9, 38:13, 38:18, again 151:6, 185:13 35:22, 57:25, 40:3, 40:17, 9:23, 20:7, accountant 58:15, 59:18, 41:4, 42:1, 26:22, 28:16, 38:25, 44:1 60:18, 66:2, 42:12, 44:11, 45:22, 46:1, accounting 73:21, 84:19, 45:10, 44:25, 49:7, 59:21, 43:15, 43:18 86:5, 86:9, 45:22, 46:9, 103:21, 112:22, 86:22, 88:13, Transcript of Howan Kwok Conducted on April 1, 2021 PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 51 of KLMNOPQRSTUSRVWXYSZ[\]^T\_`NabVcSO\deNfRcgQYgQO[LhNVO^ijQ 92
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Transcript of Howan Kwok Conducted on April 1, 2021
based 149:22, 150:19, 95:3, 96:21, benefit 150:25, 153:25, 97:5, 99:24, 173:19 5:9, 46:2, 57:7, 72:17, 154:4, 154:9, 106:3, 107:5, benefited 156:9, 158:22, 107:21, 90:14, 103:12, 107:25, 174:2 164:21, 165:18, 108:1, 108:6, 130:15, 130:20, beside 153:11 166:17, 168:11, 108:8, 127:6, 33:23 basic 174:9, 177:13, 128:11, 149:15, best 57:19 177:18 154:16, 163:9, 5:17, 19:5, basically been 183:17, 187:12 34:16, 35:3. 9:14, beqin 98:3 6:3, 41:3 11:19, 127:12 basis 12:1, bethesda 13:23, 14:1, beginning 45:15, 75:1, 3:14 14:4, 15:14, 134:14, 182:8 84:10, 162:16 betraying 15:17, 20:12, begins bates 108:3 40:23, 57:8, 22:8 160:10, 171:10 better 57:18, 62:12, behalf bathroom 116:3, 116:4 66:19, 79:18, 30:14, 30:17, 101:25, 102:6, between 79:20, 84:14, 37:2, 36:8, 154:13 4 : 4 , 6:22, 85:12, 86:12, bearing 37:5, 39:3, 13:15, 13:17, 87:9, 91:2, 39:8, 47:18, 88:13, 132:25 17:12, 20:13, 95:2, 96:3, 51:5, 70:5, because 25:17, 32:3. 96:20, 97:6, 168:18, 173:4, 6:15, 9:7, 55:9, 100:10, 100:25, 110:3, 179:8 9:13, 9:14, 144:6, 144:15, 111:7, 110:4, behavior 16:17, 17:6, 156:9, 156:10, 111:19, 111:25, 96:23 18:10, 20:12, 157:14, 166:23, 113:4, 113:5, being 24:11, 25:25, 167:9, 173:12, 113:18, 113:21, 12:16, 13:21, 26:7, 32:2, 173:24, 175:1, 114:12, 116:12, 20:21, 20:24, 34:4, 34:11, 177:1, 182:2. 118:13, 116:13, 21:3, 57:14, 36:23, 53:14, 185:25, 186:10 120:6, 122:22, 78:4, 78:5, 53:22, 54:15, beyond 124:12, 133:25, 95:5, 98:1, 55:11, 56:15, 79:24 134:1, 135:24, 99:17, 100:7, 58:19, 59:21, bhattacharya 138:7, 147:1, 103:12, 108:1, 77:16, 77:19, 3:11 149:14, 153:18, 110:4, 110:12, 77:25, 86:11, biden's 154:12, 154:14, 86:19, 93:15, 113:20, 115:19, 34:20 174:4 144:12, 147:19, 94:18, 96:11, big before 98:1, 98:10, 148:1, 148:8, 182:14 2:9, 4:15, 149:22, 167:20, 99:15, 99:22, bill 4:18, 8:5, 8:6, 171:21, 173:5, 107:23, 109:25, 51:11, 56:5, 11:13, 15:1, 176:12 112:12, 113:3, 62:21 16:21, 17:16, bejing 113:13, 114:4, billion 17:19, 17:22, 115:25, 118:18, 92:20, 93:4, 108:4, 130:21, 20:11, 22:22, 182:4 128:19, 129:2, 146:2, 146:19, 23:3, 24:7, 129:10, believe 129:11, 159:25, 160:19 24:12, 24:13, 129:20, 131:8, 24:2, 28:17, billionaire 29:1, 25:7, 132:11, 37:20, 111:14, 132:17, 162:20 44:7, 55:14, 133:7, 139:20, 127:16, 178:4, bills 56:6, 59:2, 145:19, 148:5, 178:22 29:12, 29:17, Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 55 of PQRSTUVWXYZXW[\]^X\_`abcYdeSfg[hXTaijSkWhlV^lVT`QmS[[cnoV 92
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11:14, 11:25 174:21, 174:25, 88:5, 95:7, 181:18, 183:1, care 175:22, 175:23, 114:18, 114:24, 183:9 116:1, 129:22 110:19, 126:18, 176:5, 176:16, changed 177:14, 127:10, 148:23 177:12, ccp's 9:15, 98:2 178:14, 178:16, careful 53:22, 78:1 changes 179:4, 179:21, cell 55:7 183:3 179:23, 180:3, carrier 59:6, 59:7, changing 60:13, 60:24 183:22, 184:12 61:14, 62:7, 94:4, 182:6 cases 62:18, case 62:21, chao 8:1, 14:11, 97:5, 97:7, 91:19 13:5, 8:4, 14:17, 14:19, 97:22, 98:2, 14:20, 15:2, character 14:23, 78:3, 98:4, 98:6, 16:21, 16:24, 9:9 153:7, 154:17, 98:8, 98:9, 16:25, 17:1, charged 154:20, 154:24, 98:15, 17:2, 21:4, 98:16, 15:18, 66:20 163:10, 163:11, 98:18, 98:25, 26:19, 27:4, check 167:6, 168:6, 36:8, 37:19, 99:1, 99:16, 58:16. 58:21, 168:9, 168:17, 100:2, 100:3, 43:9, 47:15, 88:4, 98:23, 168:22, 168:24, 100:7, 100:6, 47:18, 47:21, 179:12, 180:8, 169:9, 169:6, 100:8, 104:10, 48:1, 48:5, 180:12, 180:17, 169:11, 172:14, 77:18, 77:21, 104:14, 104:16, 180:23, 185:1 172:15, 172:25, 104:23, 104:24, 78:14, 80:18, checks 180:1 105:3, 105:7, 80:21, 80:22, 181:3 caught 113:20, 128:9, 81:5, 81:9, chen 100:21 128:10 83:15, 83:22, 152:7 84:18, 86:13, cause cellular cheng 150:7 60:3, 60:5 87:3, 87:17, 1:4, 6:10, caused centimeters 93:5, 93:10, 15:22, 30:10, 96:19, 111:3, 131:7, 132:11, 60:25 49:12, 31:19, 111:8, 111:10, 136:4, 146:24, certain 51:25, 77:18, 111:15, 111:17, 149:4, 149:13, 6:24, 43:11, 78:14, 80:18, 149:21, 111:20, 111:22, 151:2, 122:4, 125:15, 82:15, 82:19, 153:12, 112:13, 112:14, 151:5, 166:11, 166:12, 86:13, 87:10, 113:6, 113:8, 153:16, 154:4, 166:13 91:10, 92:7, 113:18, 113:24, 154:10 certainly 92:12, 92:13, 114:13, 114:17, caution 74:22, 109:20 92:21, 92:25, 121:6, 120:4, 16:5, 20:7, certainty 93:5, 93:8, 121:22, 123:4, 26:8, 25:4, 57:4 93:12, 93:19, 26:22, 28:15, 126:3, 139:4, certificate 94:3, 94:5, 139:8, 142:23, 31:24, 52:1, 190:1 94:6, 94:12. 143:12, 145:13, 68:22, 69:20, certified 94:22, 95:6, 146:14, 146:15, 103:22, 122:6, 2:10, 117:13, 95:25, 96:12, 147:5, 153:23, 142:25, 143:24, 190:6 96:16, 96:19, 154:3, 155:11, 163:12, 151:21, certify 96:23, 97:19, 155:17, 170:25, 173:22, 174:3 190:9, 190:15 97:25, 99:2, 171:2, 171:4, ccp chair 100:14, 101:4, 171:6, 172:4, 77:17, 77:20, 21:24 103:19, 107:2. 172:10, 172:17, 77:23, 78:1. change 107:19, 107:24, 173:5, 173:20, 78:10, 78:15, 109:6, 110:3, 19:20, 98:4, Transcript of Howan Kwok Conducted on April 1, 2021
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Transcript of Howan Kwok Conducted on April 1, 2021
comment 56:23, 57:4, computer consolidate
75:3 83:4, 86:16, 98:14, 128:5, 168 : 7 committed 91:22, 92:17, 128:6, 128:22, conspired 38:8, 41:15, 111:16, 115:12, 129:9, 129:15 114:19, 116:1 66:19, 67:3, 116:5, 131:10, concept conspiring 73:23, 73:25, 131:11, 161:15 101:23 94:13 74:3, 74:12 companies concern constantly common 12:2, 160:3, 148:23 108:22, 134:5, 82:23, 83:4 160:5, 161:1, concerning 136:3 communicate 161:3, 161:18 156:9, 182:11 constitution
83:9, 179:25 24:15, 24:17, 174:5 24:22, 27:19, communicated 102:17, 122:4, condition 27:25, 28:14, 173:12 186:18, 186:19, 126:12, 127:20 28:24, 29:3,
16:12, 16:14, comparison 15:5, 126:8 31:5, 31:14,
84:2, 90:15, complaint 148:14, 153:14 38:17, 39:22, 90:18, 103:13, 16:20, 17:5, confer 40:6, 40:20, 143:2, 144:15, 17:16, 17:19, 7:9, 148:4, 42:5,
163:15, 164:1, 17:20, 17:22, 148:7, 148:9, 42:15, 44:14, 164:3, 164:6, 18:5, 103:19, 148:11, 148:13 45:13,
164:10, 166:14, 106:2, 106:23, conference 46:1,
166:20, 176:17 107:1, 107:22, 79:14 46:22,
communications 113:5, 113:22, confirming 49:18,
16:7, 19:16, 114:13, 121:2, 58:13 67:16,
20:9, 25:6, 121:6, 121:18, confused 74:10, 75:19, 26:10, 26:23, 121:21, 132:5, 47:8, 99:22, 76:2, 76:15, 28:17, 28:20, 174:19, 183:12, 168:11 76:25,
31:23, 31:25, 188:11, 188:12, connect 91:7, 118:8, 41:10, 45:7, 188:14 64:22, 65:14, 119:11, 119:16, 45:18, 52:2, complaints 129:8, 129:9 120:1, 120:11,
68:24, 151:24 connected 120:17, 130:10,
137:3, 137:5, 129:1, 129:3, 161:23, 162:24,
73:1, 73:8, 137:7 129:4, 129:15 171:16, 172:1, 90:22, 92:3, completed connecting 181:13, 184:6,
104:1, 105:23, 136:24 129:15 185:10, 185:19 122:7, 144:1, completely connection consultant 144:2, 152:1, 72:10, 84:13, 47:2, 64:21, 12:1, 150:10, 152:4, 164:23, 89:2, 112:15 67:1, 67:10, 150:15, 150:16 165:5, 165:9, complicated 67:19, 69:5, consulting 165:12, 166:23, 54:14 69:17, 105:1, 43:18
PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 59 of NOPQRSTUVWXVUYZ[\V]^\_`aWbcQdeYfVR\_ghQiUfjT\jTR^OkQYlamlT 92
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Transcript of Howan Kwok Conducted on April 1, 2021
128:17, 128:18, discontinued document 120:20, 122:18,
128:23, 128:24, 173:6, 173:8 3:19, 18:16, 123:10, 124:4, 129:2, 129:13 discourse 18:25, 22:8, 125:11, 127:24, devices 6:22 22:13, 22:18, 128:1, 128:2, 102:22, 128:5 discovery 22:21, 23:3, 132:25, 137:10, diagnosed 170:12 24:6, 25:2, 139:2, 139:6, 127:19 discuss 32:23, 32:25, 139:8, 139:10, difference 82:14, 83:21 33:2, 33:5, 139:17, 140:5, 17:12 discussed 33:11, 33:13, 140:7, 140:11, different 19:13, 20:13, 33:17, 106:5, 140:24, 142:4,
128:10, 159:2 157:20, 160:9, 112:25, 120:24, 142:22, 142:24, dime 163:21, 165:18, 121:1, 121:10, 143:11, 143:21, 173:20 175:23, 176:5 121:14, 121:16, 144:9, 145:23, ding discusses 121:23, 122:2, 147:5, 147:12,
91:18, 159:24, 160:1 122:10, 122:21, 147:16, 147:23,
93:3, discussing 122:23, 123:5, 148:17, 154:23, 113:11, 182:2 17:3, 178:6 123:8, 123:13, 178:14, 188:21 dinner discussion 123:16, 124:6, doing
direct discussions 124:14, 125:9, 61:11, 61:16, 10:17, 43:1, 166:11 125:17, 125:20, 61:23,
92:3 dishonesty 126:16, 126:25, 84:14,
directed 15:15, 15:19 128:3, 133:4, 116:4,
53:9 dismiss 133:7, 135:16, 117:15, 117:16, directly 173:19 135:22, 135:23, 136:16, 143:3,
director 172:17, 174:7, 136:21, 136:23, doj 39:14 175:3 137:1, 137:15, 110:16, 110:17, directors displayed 137:24, 139:23, 135:18, 135:24, 39:19 100:3, 100:6 140:2, 140:4, 135:25,
directs displaying 141:1, 142:2, 144:18, 182:21 6:25 106:21, 122:22 159:24, 172:20, dollar disagree dispose 172:24, 188:11 132:13, 146:2, 69:11 99:11, 103:2, documents 178:17, 180:23,
57:17, 57:23, disposed 42:25, 54:16, dollars 95:3, 95:4, 99:21, 100:12 54:17, 54:19, 93:2, 108:3, 116:13, 134:12, disruption 54:24, 55:8, 115:6, 130:22, 145:14, 146:23 154:10 96:22, 97:3, 131:3, 132:4, disappointment district 97:4, 97:9, 146:18, 146:19,
disclosures 6:12, 155:23, 159:25, 160:19, 117:2, 122:25, 155:24, 169:25, 99:6, 100:13, 173:17, 178:20, 123:3, 188:16 178:10, 180:24, 100:24, 100:25, 178:23, 179:13,
Case 22:5007:30 - DoOSIOZAK PFiled 03/11/02/2012022113:56:18 6/2 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
183:16, 184:15, 154:21 emphasize 17:21, 18:12, 184:24, 185:5 earlier 34:5, 34:12, 112:23, 123:8 done 14:10, 39:21, 47:8, 52:21, emphasized 52:22, 52:23, 20:10, 53:24, 89:17, 99:15, 108:6 78:24, 79:2, 79:18, 81:24, 126:7, 156:1. employed 107:5, 112:25, 87:10, 110:20, 178:6, 180:15 11:25, 32:7, 120:19, easier 113:1, 122:18, 145:10, 55:24, 91:2 146:10, 151:25, 148:20 123:8, 123:9, employee 128:20, 128:21 154:1 eastern 91:17, 39:10, enormous door 169:13, 178:10, 92:12, 93:14, 153:18 110:23 180:24 94:6, 96:14, down enough easy 97:20, 97:25, 10:18, 85:19, 130:22, 12:3, 138:25 101:9, 108:13, 133:12, 138:7, 22:23, 23:1, education 108:17, 109:3, 63:16, 123:11, 138:25 89:20 109:7, 110:17, 157:15 113:12, ensure effect 114:9, 6:21, 7:4, downloading 131:13, 132:24, 4 : 1 7 43:3 120:20 135:1, 135:2, effort downstairs 135:18, 144:17, entered 91:24 145:15, 36:7 54:23 146:8, efforts 149:21, 149:24, entire drinking 102:25 153:17, 181:22 88:2, 99:18 76:5, 115:4 eight drive employees entirely 81:17 3:5 57:16, 57:21, 172:10 69:11, either 96:12 entitled driver's 9:18, 12:25, employment 10:1 106:22, 120:6, 13:12, 53:2, 12:2, 89:24 160:17, 188:11 duly 74:19, 80:12, empty entity 190:12 6:3, 80:18, 80:19, 65:10 57:9, 186:21 duplicated 97:17, 98:2, encouragement entrepreneur 9:14 107:4, 122:17, 91:24 during 142:10, 161:17, 171:11 end 177:22 equivalent 21:2, 94:24, 92:18, 110:1, electronic 34:13 98:22, 98:24, 100:5, 107:1, 172:21, 127:12 100:9, erased endorse 101:6, 105:21, 174:25 134:11 105:24, 134:15, eliang 180:23 escape 155:6 151:16 enemy 129:21 elicit 57:16, 78:2, esq E 115:11, 115:13, 72:25 3:7, 3:8, 3:15 e-mail eliminating 115:15 establish 65:20, 65:22, engaged 82:24, 83:4 25:7, 93:21 65:23, 65:24, 156:13, 156:16 elliott established 66:2, 66:3, engaging 78:4 71:17, 90:5, 66:5, 104:19, ellis 148:4 148:16 105:2 english 179:10, 179:14 estimate each 5:15, 5:16, else 157:23 6:16, 105:3, 17:7, 6:19, estimated 80:22, 82:6, 108:5, 108:8, 17:8, 17:15, 112:1 136:5 PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22:5007:30 - DoOSIOZAK PFiled 03/11/09/22/2113:56:18 63 dPage 63 of 92
Conducted on April 1, 2021 ethnicity 147:2, 183:23, 121:15, 121:17, 158:6 185:25 122:2, 122:22, faces 158:19, 159:2, 159:8 exact 122:24, 123:23, 158:7 123:24, 123:25, evaluated 70:25 fact 124:21, 127:22, 153:9, exactly 78:9, 153:11 78:20, 188:5, 188:7, evaluation 77:17, 77:22, 87:9, 91:15, 188:8, 188:11, 95:3, 97:1, 153:13 78:10, 88:4, even 95:25, 96:1, 188:12, 188:13, 97:8, 97:22, 188:15, 188:17, 52:25, 101:13, 109:5, 97:24, 98:21, 6:18, 142:19, 189:1, 189:3 113:7, 104:15, 110:9, 54:18, 65:25, exhibits 165:22, 177:9, 110:13, 111:19, 71:16, 78:21, 186:4, 186:10 186:22 113:25, 114:16, 86:22, 100:23, exist exam 115:9, 154:14, 116:3, 146:18, 60:6 169:5, 153:16, 156:19, 188:2 160:6, examination expect 184:18 166:17, 172:10, 180:6, 182:13 6:5 164:18 facts expensive 122:5, 153:12 event example 92:22 factual 34:7, 182:6 34:19, ever 56:4, 87:13, explain 94:18, 115:9 faith 7:16, 144:14, 144:16, 137:22 11:21, 144:25, 14:12, 145:25, explaining 131:1, 131:21, 32:24, 146:1, 151:3, 132:21, 52:9, 52:12, 106:13 146:15, 63:13, 65:23, 156:23 explanation 147:2, 153:22, excellent 154:2 65:24, 66:3, 137:25 66:19, 116:25, 139:13, false 69:16, exploring 140:16 46:7, 70:3, 91:2, 85:1 46:16, 102:9, 102:16, except 46:25, 67:9. exposing 103:4, 105:6, 4:9 71:5, 71:6, 88:9 123:5, 138:21, 73:9, 183:13 exception extends 138:23, 161:17, familiar 42:19 164:2 169:3, 180:17, 8:21, 15:21, excess extent 180:22 17:8, 23:8, 132:3 31:21, 69:22, every 43:15, 47:5, exchange 90:14, 90:17, 24:11, 21:1, 48:17, 111:17, 93:14, 173:5 103:11, 103:24, 59:22, 98:3, 160:21, 177:2 excuse 104:3, 122:8, 98:4, 101:9, family 114:22, 130:3, 130:5, 130:11, 129:21, 129:24 66:18, 67:3, 133:17, 133:18, 144:2, 151:22, everybody 77:7, 78:19, 133:19 152:2, 153:2, 55:22, 55:24 86:15, 86:21, executed 163:13, 163:25, everyone 87:4, 87:14, 14:4, 24:3 164:4, 166:8, 57:20 101:8, 101:12, exhibit 166:10, 167:7, 114:7, 131:6, everything 173:10 18:21, 18:23, 182:11 65:10, 66:11, 19:2, 19:8. F family's 184:9 22:11, 22:14, fabricated 108:21, 131:8 evidence 32:20, 33:14, 66:1, 111:15, 96:15, 113:4, far 106:20, 106:22, 132:25, 133:6 57:13, 83:14, 113:18, 114:23, 112:20, 112:24, face 105:20, 161:7 144:16, 146:16, 120:25, 121:2, 132:4, 156:23, Case 22:5007:30 - DoO5I6231KPFileDd3/119/2254 EnteFieedO301133221137569164 of 92
fatal 50:13, 50:19, filibuster 120:19, 176:20
151:6 74:20, 74:23, 109:21, 109:22, 55:16, 80:3, fear 75:3, 75:6, 134:23, 136:19 94:17, 101:3, 108:23, 131:7, 75:18, 76:1, filing 109:14, 124:3, 131:15, 132:16, 76:14, 76:24, 4:6, 168:22 124:8, 124:23,
february 90:11, 90:19, 39:8 153:6, 169:3, 154:18, 163:10 91:6, 118:7, filling 172:6, 188:20,
12:18, 38:22, 119:15, 119:25, filthy fiscal
44:10, 67:10 130:10, 153:4, finance fit federally 159:17, 159:22, 120:13 28:10
36:12, 48:1, 163:5, 169:17, financing 15:17, 40:23, 48:5, 49:4, 171:15, 171:25, 175:21 41:25, 157:4,
feel 184:5, 185:9, 56:8, 58:17, five-minute
86:19, 185:18, 187:4 62:20, 78:12, 102:6 88:11, 180:1 fifty-nine 85:6, 101:2, fix
female 141:12 145:22, 160:7, 22:3, 180:10 158:14, 158:23, file 177:19, 177:21, folks 159:1 40:10, 42:25, 179:2, 179:20 180:15
12:9, 12:21, 15:24, 16:2, 102:1, 117:15, 6:4 13:10, 24:21, 16:21, 17:17, 154:11, 164:20 force 27:18, 27:24, 17:19, 17:23, finished 4 : 1 7 28:13, 28:23, 43:23, 102:4, 95:20, 109:11, forensic 29:2, 29:8, 106:3, 107:1, 127:16, 133:22, 102:17 30:5, 30:20, 107:5, 107:22, 133:23 form
40:5, 40:19, 168:17, 168:24, 37:14, 37:18, 18:2,
41:7, 41:17, 169:7, 169:9, 37:24, 43:16, 23:12, 23:23, 42:4, 42:14, 169:11, 169:19, 43:18, 47:5, 24:8, 25:12, 44:13, 45:2, 171:21, 172:13, 47:15, 48:1, 25:16, 26:22, 45:12, 45:25, 172:20, 174:13, 49:5, 49:8, 27:8, 27:14, 46:11, 46:21, 178:9, 181:5 49:10, 56:2, 27:20, 29:6, 48:12, 49:17, files 101:17, 101:21, 29:14, 32:22, 50:6, 50:11, 38:22 102:3, 107:11, 33:25, 34:3,
Transcript of Howan Kwok Conducted on April 1, 2021
Case 22:5007:20-DoO516231KPFiledd03/119/2254Enteried003113722113:569865 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
49:2, 56:9, 14:16, 147:8, function generate 56:13, 56:20, 154:17, 163:10, 104:25, 129:7 49:25
104:9, 104:21, frame 71:21, 137:3 3:13
115:23, 119:19, frank 56:23, 56:25 58:7,
138:1, 139:5, fraud 51:2, 176:23 97:21, 101:1,
140:18, 142:17, 45:21, 73:24, 39:17 getting 143:18, 144:13, 74:1, 74:3, further 51:2,
156:7, 156:18, 96:22 157:15, 190:15 173:20
160:12, 161:4, 16:12, 122:9, g-e-t 93:2 172:23, 173:21, 144:4, 152:4, 59:3 qifting 173:22, 175:25, 163:17, 164:6, g-e-t-e-e-r 182:4
180:19, 180:20, 165:6, 166:9, 58:21, 58:23 gifts
54:21, 55:2, friends gauge 68:20, 123:15, 93:24, 144:21, 54:25, 86:15, 149:12 134:20, 139:13,
86:1, 111:4, 123:18, 128:12, 14:10, 70:1, given 111:11, 111:15, 128:16 115:25, 116:2, 9:12, 9:15, 112:14, 113:6, frozen 140:22, 141:6, 11:22, 14:25, 153:22 160:19 178:2, 183:14 93:1, 93:16, forwarded fugitive gavenman's 115:5, 181:16, 133:25, 134:2 160:18 51:16, 51:18, 190:14
127:6, 177:13, 101:8, 112:15, general 136:11 177:15, 177:18, 131:1, 131:17, 7:1, 26:12, giving 180:6 132:17, 132:21, 26:15, 141:9, 96:21,
foundation 159:4 142:10 136:16, 136:22
PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22:5007:30 - DoOSIOZAK PFiled 03/11/02/2012022113:56:18 6 of age 66 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
glass 164:24, 182:21, 58:11, 58:22 185:6, 185:8, 76:6 187:1, 187:2 guarantee 185:14, 185:17, gone 117:6 185:21, 186:1, go 117:3, 186:11 88:18 quess 11:3, 17:5, 51:18, 7:12, quo's qood 54:7, 66:12, 54:13, 58:21, 6:7, 6:8, 157:22 12:19, 22:15, 117:20, 24:18, 30:3, 63:16, 72:4, 117:22, guests 79:8, 79:9, 131:1, 131:21, 81:19, 81:20, 30:18, 31:2, 132:21, 37:7, 31:11, 79:11, 83:16, 146:15, 81:25 84:6, 85:16, 147:2, 153:21, 38:1, 38:14. guo 40:3, 41:5, 85:25, 88:3, 159:6, 166:4, 1:7, 8:3, 12:8, 42:2, 44:25, 88:25, 89:1, 167:19 12:20, 14:19, 90:6, 45:10, 45:23, 89:4, google 22:18, 22:25, 46:9, 48:10, 93:10, 101:24, 136:2 23:7, 24:19, 118:18, 118:21, gossipped 49:15, 50:4, 30:3, 30:19, 67:13, 76:12, 122:20, 123:20, 135:4 31:3, 31:12, 124:20, 127:1, 90:1, 118:5, qotten 37:7, 38:1, 135:22, 121:18, 122:25, 144:11, 38:14, 40:4, 62:14 124:1, 124:22, 145:22, 148:17, government 40:18, 41:5, 185:16, 188:8, 154:8, 154:16, 42:13, 44:12, 12:18, 9:18, 188:15, 160:13, 166:24, 188:13, 44:20, 45:1, 12:25, 44:10, 185:5 188:17, 189:3 185:4, 45:11, 45:23, 44:17, 67:11. goal qust 69:17, 74:5, 46:10, 46:20, 118:19 82:23, 83:4 93:9, 48:11, 49:16, 92:20, god 50:5, 67:13, H 93:16, 94:1, 154:22 70:22, 72:20, 94:13, 110:19, h-a-o-y-u-n goes 133:2, 133:5. 73:4, 74:8, 11:22 74:11, 75:17, 166:23 133:6, 133:9, h-a-y-u-n 75:25, 76:13, going 150:6 11:18 76:23, 80:10, 7:3, 10:13, governors h-o-w-a-n 91:5, 90:2, 10:16, 10:18, 186:16 8:14, 9:22, 25:4, 96:4, 102:9, 22:7, grand 11:16, 11:12, 106:25, 107:19, 26:22, 26:21, 14:1 11:20, 16:4 107:24, 118:5, 28:15, 44:18, great ha 119:9, 119:14, 53:22, 61:8, 87:8, 88:10, 8:4, 14:20 62:4, 68:22, 119:24, 120:9, 131:7, 154:2, hack 120:15, 121:5, 69:19, 74:14, 161:9, 165:19 97:18 74:16, 123:2, 134:5, 75:2, groceries hacked 159:15, 159:21, 79:23, 86:1, 76:8, 76:11 59:21, 59:22, 160:18, 161:21, 86:3, 87:12, grounds 59:23, 59:24, 90:6, 161:24, 162:22, 93:13, 13:10, 13:9, 97:6, 97:22, 163:4, 167:3, 106:5, 106:6, 68:4 98:2, 99:1. 169:16, 171:14, 109:16, 109:17, group 99:6, 99:16, 171:24, 178:11, 134:7, 134:10, 52:13 3:3, 99:17, 100:2, 180:9, 181:11, 134:11, 134:19, grow 100:7, 100:9, 183:12, 184:3, 148:19, 149:6, 42:3 102:11 184:15, 184:16, 149:8, 154:3, gtv hacker 184:24, 185:1, 154:12, 154:14, 21:7, 58:7. 100:10 Case 22:5007:30 - DoOSIOZ31KPFileDd3/119/02/113722113:56:167 dPage 67 of 92
160:1, 160:25, hatred 190:21 47:6, 47:25
hand hear 135:18, 146:19, 62:12, 154:13
handed 112:3, 138:13, 101:16, 102:3 8:7,
140:19, 140:21, 139:21, 154:11, hired 160:2, 187:9, 177:15, 177:17, 160:7, 164:24 155:20, 156:5, 190:10
handling 11:17, 143:1, hit 92:18, 100:24, 96:19, 179:25 169:3 106:7 107:20, 140:1,
53:10, 59:14, 2:8, 89:22, 151:12, 152:8 human
86:5, 88:15, 93:12, 86:4, 134:22, 104:10, 115:5, 99:13, 154:7 167:20 155:2 158:3, 158:7
166:12, 166:13 105:7 59:4, 179:7 93:7, 93:16, happened helping holthus 104:13, 134:3
harassing 144:7, 147:3, 96:16, 96:25, 166:4, 166:18, 62:9, 83:19, 148:2, 150:17, 97:1, 97:15, 168:15, 169:12 84:8, 84:12, 154:15, 156:23, 149:14, 159:25, identification 126:24, 136:3 157:20, 179:23, 160:19 9:17,
harassment 179:24, 184:1, hooligan 9:24,
78:17, 101:11, 4:3, 4:7, 190:9 hooper 121:3, 121:19, 146:25, 149:5, herein 3:19, 18:15, 123:1, 124:4,
151:1, 153:11 hereinbefore hope identify
Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 68 of NOPQRSTUVWXVUYZ[\V]^\_`aWbcQdeYfVR\_ghQiUfjT\jTR^OkQZ\almT 92
! - " - " # - - - -- --- ---- --- -- -- - - - - -- - -- # # - - - - \$ -
- %&'()\&+,-./0.1'(21.3 4.(56\-75.(8,&+9:;<=<: >? @A8BC%DC@EF GGGHIJJHJ?>?KLLLH@A8BC%DC@EFH4EM Case 22:5007:30 - DoOSIOZAK PFiled 03/11/2020 11:56:18 08/12/2022113:56:18 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 92
Conducted on April 1, 2021 141:20 118:6, 118:12, 10:10, 35:8, 114:17, 167:15, 119:15, interrogatories 119:10, 50:17, 71:8, 179:10, 179:14 120:10, 124:24, 125:2, 119:25, 136:14, 162:15, judgment 130:9, 167:19 30:13, 170:14, 170:17, 120:16, 30:11, 159:16, 159:22, jeff 171:2, 189:6 30:17, 52:6, 161:22, 162:23, 12:23, 28:11, interrogatory 52:7, 52:10, 163:5, 169:17, 34:10, 176:15, 181:9 42:16, 140:8, 171:4, 171:8 171:15, 171:25, 50:8, 61:17, judgments 181:12, 184:5, 69:25, 86:7, interview 175:22 185:9, 185:18 98:22, 98:23, 118:9, 156:23. juliet involve 156:24, 156:25, 98:24, 100:4, 3:19, 120:23, 32:2 167:17 130:16 100:6, 123:21 involved jeffrey interviewed july 37:1, 3:15 95:2, 98:22 53:22 101:6 involving jersey interviewing jumping 94:24 15:15, 15:18, 2:11, 168:12, 123:21 78:14, 182:9 190:2, 190:9 interviews iun iphone jian 116:12 152:7 introduced 105:9, 105:12 91:19 june jianbin irony 185:25, 186:10 92:8, 99:25, 153:24 151:13 investigation 101:6, 108:14. jinping irrelevant 41:2, 41:14 110:1 27:3, 77:21, 108:3, 182:15 invocation junk 84:14, 87:3, job 79:17, 162:1, 89:3 87:16, 89:2, 1:17, 89:22, 162:3 jury 180:3 89:25, 90:10, invoke 14:1, 121:2, irresponsible 90:24, 115:22, 67:20, 90:11 121:6, 188:12 34:24 115:24, 115:25, invoked justice irresponsibly 117:15, 116:2, 39:21 45:21, 78:4, 27:3 117:17, 117:20, invoking 131:14, 132:25, 150:15, issue 117:22, 134:7, 135:14, 12:9, 12:21, 150:16, 175 : 7 50:12, 50:14, 150:1 24:20, 30:4, jobs 71:1, 81:22 30:20, 31:4, K issued 150:10, 150:21 31:13, 37:8, k-w-o-k joining 9:18, 38:2, 38:15, 10:1, 8:12, 8:14, 79:9 10:5, 52:6, 40:5, 40:19, 9:7, 11:12, joke 41:6, 111:7 41:16, 11:16, 16:4, issues 157:19 42:4, 42:14, 17:13, 18:1 127:4, 187:3 jolley 44:13, 45:2, keep 45:12, 45:24, itself 101:17 88:24, 99:19, 46:11, 164:12, 164:15 jonathan 46:21, 129:20, 130:1, 48:12, 49:17, 151:12, 152:6, J 148:19, 150:5, 50:6, 50:19, 152:8 150:6, 157:22, janover 74:9, 67:14, judge 43:16 169:8 74:23, 75:6, 79:15, 79:19, kept japan 75:18, 76:1, 86:23, 87:19, 108:17, 128:3, 93:20, 149:14 76:14, 76:24, 88:14, 88:16, 135:2 jay 90:3, 91:6, 88:22, 88:25, 3:7, 6:9, PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22:5007:30 - DoOSIOZAK PFiled 03/11/02/22/2113:56:16 0 dPage 70 of 92
kidnap 12:12, 13:8, 9:1, 15:24, 158:22, 159:1, 78:6 13:19, 16:6, 16:2, 27:13, 159:7, 159:9, killer 18:9, 18:13, 28:14, 29:10, 159:13, 163:22, 19:5, 47:9, 47:12, 167:5, 176:17, 132:19 19:11, 43:8, 50:21, 48:9, 49:11, 177:12, 177:16, killers 66:10, 75:11, 113:6, 113:9, 177:17, 177:24, 108:2 89:10, 127:23, 131:1, 169:19, 178:1 kind 130:7, 160:2, 170:14, 175:9, learn 21:15, 34:23, 180:10, 187:9, 175:13, 175:16, 167:17 53:24, 54:14, 188:3, 190:10 178:9, 183:10 least 55:7, 59:7, lawsuits L 14:11, 35:21, 64:10, 86:25, 28:22, 53:21, 78:19, 130:22, 87:1, 88:11, lake 82:18, 174:13 150:14, 166:6, 93:21, 94:2, 3:5 lawyer 170:10 96:1, 97:8, language 6:24, 16:18, left 108:23, 128:18, 6:21, 17:15. 131:15, 131:20, 23:20, 23:22, 59:16, 61:2, 54:20 17:22, 25:10, 25:11, 94:5 133:13, 134:16, large 26:11, 28:11, legal 134:18, 136:3, 96:21 34:21, 36:4, 144:16, 146:4, 3:3, 52:13, las 146:24, 36:9, 36:13, 54:11, 55:10, 149:12, 3:6, 93:18, 51:15, 53:15, 150:2, 150:11, 117:10, 117:14, 130:14 55:25, 56:17, 167:9, 173:11 150:13 last 59:21, 64:18, let's kindness 8:9, 8:13, 65:4, 65:6, 134:14 18:22, 62:10, 8:17, 14:5, 78:21, 96:19. 71:20, knowingly 89:4, 15:14, 15:17, 97:11, 97:13, 102:2, 120:23, 67:9, 46:16, 18:12, 29:1, 110:2, 113:23, 70:22. 73:16 121:13, 122:20, 29:5, 29:9, 116:9, 117:15, knowledge 123:20, 124:20, 40:23, 41:25, 117:16, 117:20, 127:1, 155:3 19:6, 41:3, 89:7, 89:22, 117:21, 140:19, 57:19, lethal 71:2, 89:24, 90:10, 140:22, 140:25, 146:13 113:8 125:22, 126:5, 141:6, 141:8, letter known 126:15, 127:8, 141:11, 142:13, 44:16, 56:5, 135:13, 88:14, 127:22, 152:21, 142:16, 155:7, 152:7, 138:15 169:10, 155:6, 163:9 155:17, 156:12, 170:21, 170:22, letters later 157:21, 156:14, 175:20 17:12, 53:18. 94:19, 99:15, 165:20, 165:21, 54:2, knows 53:19, 145:9, 145:12 166:24, 166:25, 71: 6 54:3, 54:9, law 167:2, 174:1, 61:2, 61:3 kong 33:18, 47:5, 178:2 level 9:11, 9:13, 47:15, 47:25, lawyers 96:16, 96:25, 89:19 49:5, 49:8, 33:23, 34:2, li 97:1, 97:15, 49:10, 56:2, 51:9, 64:24, 149:14, 91:19 159:25, 71:9, 66:22, 117:22, 127:25, 160:19 lian 71:12, 71:15, 128:4, 153:14, kwok 91:19 101:17, 102:3, 155:20, 156:13, 1:12, 2:8, 6:1, liang 120:19 107:11, 156:15, 156:21, 6:7, 8:7, 8:18, 151:14, 152:16 lawsuit 157:1, 158:3, 8:19, 11:7, liar 8:20, 8:24, 108:19, 109:5, Transcript of Howan Kwok Conducted on April 1, 2021 PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22:5001:20 - DoO5I6231KPFileDd3/19/2254 Enteried:03/12822113:56:16 1 dPage 71 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
life 99:22, 168:11 113:9, 113:21, 51:6,
77:22, 87:14, live 113:23, 153:25 64:21,
88:2, 101:12, 77:6, 77:10, 12:2, 54:19, 95:24,
31:10, 38:9, lives 130:18, 146:22, 135:5, 145:16,
line 22:16, 22:19, 114:2, 114:4, 52:13,
88:18, 15:22, 124:2, 94:3, 94:6, 180:9, 180:13,
95:9, 124:23, 188:19, 94:16, 94:18, 180:16
165:23 107:25, 138:7, 110:6, 113:10, mails link 149:7, 149:8 114:11, 115:9, 52:24, 53:3 43:2, 64:17, longest 115:22, 115:24, mainland 65:13, 65:15, 90:25 115:25, 116:7, 9:10, 96:20, 65:17 look 116:16, 116:17, 96:24, 97:10, list 55:14, 111:19, 130:14, 145:2, 111:12, 115:2, 57 : 8 143:11, 143:14, 177:1, 177:6, 134:1, 145:1,
65:7, 65:13 looking 110:25, 111:2, 36:25,
litigation 60:23, 61:20, 111:10, 111:12, 70:25,
28:5, 49:6, 111:24, 111:25, 111:18, 111:24, 88:14,
Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 72 of LMNOPQRSTUVTSWXYZT[\]^\_U`aObcWdTP]efOgSdhRZhRP\MiOYR\_jkR 92
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=>6?@#A@=BC DDDEFGGEG<H<IJJJE=>6?@#A@=BCE2BK Case 22:5007:20 - DoOSIOZAK PFiled 03/11/09/22/2113:56:16 3 dPage 73 of 92
miles mitchell motivation name 118:11 6:9, 13:8, 18:9, 35:6, 36:2, 8:7, 8:10, 79:8, 180:10 36:7, 36:11, moutai 8:13, 8:15, million 155:16, 155:21 8:17, 8:21, 9:4. 92:22, 115:4 96:17, mo 9:6, 9:12, 9:14, 115:5, move 132:13, 151:13, 187:13 9:15, 11:10, 62:10, 79:24, 151:14, 11:15, 11:22, 151:15, moment 79:25, 88:23, 151:16, 151:17, 16:3, 16:17, 18:24, 22:9, 108:24, 138:2, 18:5, 43:2, 18:1, 152:6, 152:13, 35:21, 138:17, 147:21, 152:15, 152:16, 59:5, 106:19, 184:22 18:9, 18:12. 167:22, 22:25, 23:17, 152:17, 152:21, 118:19, 149:11, moved 29:13, 34:9, 152:22, 157:12, 149:17, 152:24 127:3 34:20, 34:24, 157:15, 160:1, momentarily moving 35:22, 36:21, 160:25, 173:17 79:10 106:12, 125:4, millions 47:7, 48:20, money 183:10 49:7, 93:1, 93:7, 49:3, 115:18, 179:8, msn 93:17, 57:21, 58:11, 108:2, 98:20, 104:6, 184:2, 185:4, 115:6, 58:17, 58:22, 134:2, 185:14 104:18, 104:25, 60:5, 61:21, 134:3, 146:18, mongolia 105:1 91:18, 97:13, 146:25, 150:14, 130:19 much 93:5, 97:15, 138:14, 150:22, 182:5 mongolian 12:6, 42:9, 152:6, 152:21, mind 93:9, 95:5, 101:11, 104:16, 156:19, 170:20, 73:14, 100:20, 115:2, 116:10, 116:4, 119:12, 170:24, 172:7, 101:24, 128:14, 128:16, 116:11, 130:15 119:22, 131:8, 139:20 176:8 monies 132:12, 132:15, named mine 132:3 132:16, 137:21, 23:8, 35:6, 22:5 month 149:19, 151:1, 36:6, 36:9, minister 153:21, 154:4, 29:2, 29:4 36:13, 36:16, 182:20 185:14, 187:5 months 43:16, 47:5, ministry must 99:24, 107:21, 48:17, 115:22, 182:20 111:25 101:19, 109:24, 178:11 minor 116:6, 122:10, more names 131:2 125:7, 138:11, 7:21, 20:12, 34:4, 34:15, minutes 71:20, 172:6 72:9, 47:8, 58:1, mute 21:13, 21:14, 102:17, 104:16, 80:9, 101:20, 79:9 62:13, 72:13, 114:16, 153:18, 101:21, 101:22, 170:11 myself 157:4, 157:6, 116:18, 116:20, mischaracterizes 17:6, 20:13, 157:8, 157:10, 116:21, 134:18, 85:17 158:2 25:17, 53:4. 151:19 57:14, miss 53:5, morning narcotics 106:9 101:7, 103:3, 6:7, 6:8, 21:8, 15:10 mistake 129:12, 131:5, 58:5, 65:7, narrow 144:6, 144:8, 34:23, 100:1 66:6, 160:17. 157:15 156:10, 163:18, mistaken 161:14 nation 33:1, 34:19 most 173:24 55:12 N mistaking 6:21, 84:15, national 34:24 109:20, 184:20 n-u-o 57:15 mostly misunderstood 170:21 140:14 107:23 Transcript of Howan Kwok Conducted on April 1, 2021
Case 22:5001:30 - DoOSIOZAK PFiled 03/11/02/2012022113:56:16 4 dPage 74 of 92
native 17:1, 17:2, 55:25, 56:2, notice 6:20 17:16, 17:23, 56:22, 56:25, 17:25, 19:2, natural 18:6, 30:11, 59:25, 63:19, 19:7, 111:6, 48:22, 31:20, 67:11, 72:1, 34:11 188:7 49:5, 49:11, 74:6, 113:23, naturally november 52:7, 52:10, 120:2, 120:5, 99:23, 171:21 110:11 80:18, 80:22, 120:13, 155:24, nearly nowadays 88:23, 89:4, 162:5, 168:12, 55:4 59:22, 98:4 102:4, 102:20, 169:25, 172:21, necessarily number 103:20, 106:2, 174:17, 174:21, 57:15, 10:16, 55:17 6:16, 107:2, 107:10, 175:1, 176:2, need 62:1, 62:7, 114:13, 118:1, 180:10, 180:11, 62:25, 78:2, 7:3, 7:6, 118:24, 120:5, 190:2, 190:8, 91:16, 104:24, 13:14, 19:12, 120:19, 131:1, 190:9 120:24, 124:20, 19:23, 25:7, 145:13, 146:15, newspapers 160:10, 171:8, 53:17, 55:19, 176:15 92:1 188:6, 189:2 58:20, 58:21, nevada ' s next numbered 59:25, 61:13, 113:6 135:10 74:1, 90:13, 124:11 never nice 98:4, 109:14, numerics 33:2, 51:12, 134:16 22:25 112:11, 112:22, 65:24, 66:3, nine 112:23, 113:3, nv 73:25, 74:12, 21:13, 21:14, 113:15, 118:17, 3:6 102:12, 111:12, 81:17 118:20, 135:22, O 136:25, 137:2, 111:13, 111:18, nods o-k 111:21, 133:3, 137:16, 7 : 4 144:23, 8:14 134:19, 134:11, none 146:9, 146:12, oath 142:9, 157:21, 149:7, 151:19, 112:19 4 : 16 175:23 154:8, 159:7, nonetheless object new 167:17, 173:25, 7:2 5:8, 26:21, 1:2, 2:11, 174:1 nonlawyers 60:18, 62:4, 6:12, 10:2, needed 56:18 90:13, 160:11, 23:24, 24:14, 54:12, 110:13, nonresponsive 175:25 25:10, 25:24, 110:18 137:8, 138:3, objected 30:14, 30:16, needs 180:7, 184:22 127:2 31:1, 31:10, 50:20, 51:6, normal objection 32:8, 32:12, 143:5 20:10 8:23, 10:10, 33:20, 38:9, negotiate notarize 10:25, 14:13, 38:12, 38:22, 180:22 33:17 18:2, 18:7, 39:4, 39:1, net notarized 23:12, 23:23, 39:11, 39:7, 163:2 178:6 24:8, 25:12, 39:14, 39:18, netherland notary 25:16, 27:8, 39:24, 40:1, 22:2 33:20, 2:10, 27:14, 27:20, 40:14, 40:25, network 190:7 29:14, 29:6, 43:20, 44:9, 101 : 1 note 32:22, 33:25, 45:8, 46:8, neurologist 58:20, 123:2 34:3, 34:17, 46:17, 49:22, 126:19 noted 35:16, 41:8, 49:24, 50:3, nevada 179:12, 187:6 43:13, 44:5, 50:23, 51:1. 15:25, 16:25, nothing 58:20, 103:17 Transcript of Howan Kwok Conducted on April 1, 2021 Case 22:5007:30 - DoOSIOZAK PFiled 03/11/02/2012 12:56:18 6 5 of 92
45:15, 46:2, october 39:16, 42:23, 134:14, 143:5, 48:23, 49:1, 91:12 43:1, 43:2, 143:6, 144:23, 56:9, 56:12, office 59:11, 61:21, 146:16, 147:3, 56:20, 66:2, 78:2, 150:4, 151:4, 57:24, 32:11, 32:14, 69:6, 70:17, 82:6, 90:8, 172:14 32:16, 59:15, 71:1, 72:17, 90:9, 96:25, open 59:17 73:7, 73:19, 100:20, 102:16, 98:11, officer 113:24, 80:6, 92:4, 4:15, 105:4, 106:18, 118:19, 146:12, 31:9, 103:10, 104:9, 113:10, 122:15, 149:23, 154:8 39:13, 39:23. 104:21, 107:15, 128:11, 131:22, 176:12 opened 115:23, 112:21, 141:6, 142:5, 110:22 officers 144:24, 119:19, 129:18, 146:6, openly 39:19 138:1, 139:5, 152:9, 152:24, 110:12, offices 110:20, 139:15, 139:18, 153:15, 154:16, 32:17 135:18, 136:2, 140:18, 142:17, 156:20, 161:8, 144:22, 145:20 offshore 143:18, 144:13, 168:12, 168:13, operating 160:3, 160:4, 145:24, 168:14, 168:22, 147:7, 18:11 161:1, 161:2 147:13, 150:24, 168:25, 169:7, opportunity oh 154:19, 155:8, 172:14, 174:12, 114:16 165:19 156:7, 156:18, 175:2, 184:18 opposed ok one-minute 158:15, 160:12, 33:19 9:2, 10:23, 161:4, 162:6, 21:13, 21:15 18:25, 19:22, order 172:23, 173:21, one-year-old 6:21, 19:24, 35:13, 7:4, 173:22, 180:19, 34:13 127:3, 159:25, 42:24, 43:1, 180:20, 183:18, ones 161:1, 161:6, 58:24, 61:1, 186:5 140:13, 180:16 180:7 81:11, 81:24, objections ongoing 84:11, 86:8, ordered 4:9, 6:25, 111:22, 174:6 179:11 96:9, 97:13, 124:1, 85:23, online original 100:12, 102:6, 124:22, 170:13, 57:18, 58:2, 105:20, 106:9, 107:1 188:18, 189:4 78:11, 87:7, 114:25, 115:24, other obligation 87:12, 88:3, 122:21, 123:20, 6:17, 14:23, 69:4, 71:11, 114:8, 116:22, 124:20, 127:9, 15:1, 20:17, 103:8 135:19, 136:2, 132:2, 144:14, 20:20, 28:14, obligations 144:19, 144:23, 183:3 28:22, 29:9, 170:8 145:11, 145:12, old 32:17, 33:20, observe 145:18, 145:19, 3:13, 54:25 33:23, 34:2, 18:4 181:23 omitted 35:9, 61:21, obstruction only 124:12 79:25, 80:22, 167:16 22:24, 34:11, once 83:18, 91:18, obstructive 58:10, 69:7, 15:23, 98:3, 108:5. 17:5, 70:9 70:17, 71:2, 45:22, 46:1, 108:8, 112:5, 93:19, obtain 81:18, 116:17, 116:18, 99:16, 91:10, 65:2 104:23, 114:1, 120:13, 128:5, 148:15 114:4, obviously 114:3, one 130:15, 155:6, 115:10, 115:13, 183:23 28:6, 155:15, 155:16, 8:6, 9:9, 9:10, 117:17, 131:2, occurred 155:18, 155:20, 18:24, 22:9, 131:24, 132:1, 163:14 157:1, 158:7, 28:2, 28:6, Transcript of Howan Kwok Conducted on April 1, 2021
Case 22:5001:30 - DoO5I6231KPFiled@3/119/02/113722113:56:16 dPage 76 of 92
172:15, 172:25, 12:4, 50:10, 181:9, 183:24 174:13, 175:2, pacific 53:23, 56:23, payments 176:11, 179:25, 8:3, 14:20, 57:4, 57:9, 36:25, 39:7, 181:2 47:11, 48:8 57:15, 65:25, 40:13, 51:4,
82:12 125:4, 188:2, 111:16, 115:12, 29:22, 76:18 otherwise 188:6, 189:2 116:5, 131:11, peak 97:6, 175:22 pages 131:12, 161:15, 100:9
33:13, 56:8, 12:6, 30:14, 86:16 182:13, 182:14
108:14, 117:17, 133:13, 175:22, 82:4, 132:10, 7:8, 133:20, 120:24, 127:7, 184:14, 184:23, 132:11, 142:18, 135:10, 137:6, 145:20, 179:2, 184:24 150:9, 177:14 154:20, 187:3
out-of-your-juri- paragraph paused 54:11,
sdiction 107:18, 183:11 79:7 54:25, 56:15,
outcome 28:7, 31:19, 78:23 91:16, 91:18,
outside 147:11, 153:22, 29:20, 29:24, 95:3,
32:8, 72:10, 163:25, 174:6 30:16, 36:20, 106:9, 108:4, 144:3 particular 37:4, 37:18, 115:13, 115:14,
124:10, 124:14, 10:14 76:20, 118:14, 146:22,
135:19, 180:23, 118:23, 119:7, 149:16, 150:8, 186:3 parties 159:13, 176:14, 153:19, 155:18 overbroad 4:5, 6:2, 55:1, 185:14 people's
30:25, 58:16, 115:20, 184:17 47:23, 51:22, 43:17, 43:22, 75:22, 86:20, partners 62:21, 132:22, 54:20, 101:14,
owner 83:3, 149:15 payment 123:17, 131:24, partnership 36:25, 51:6, 134:3, 157:23, 81:20, 82:1 85:11 173:5, 173:9, 159:4, 161:12,
Transcript of Howan Kwok Conducted on April 1, 2021
PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22:5001:30 - DoO5I6231KPFiled@3/119/02/129122113:56:16 7 dPage 77 of 92
101:6, 104:15, 59:24, 59:25, 130:6 23:22, 25:2, 138:15 60:1, 60:20, piecemeal 25:9, 25:15, perjury 61:15, 62:1, 74:18 25:22, 26:3,
person 64:12, 65:20, 98:24 32:7, 33:4,
59:16, 64:6, 84:24, 84:25, 1:5, 3:4, 6:10, 33:19, 33:24,
93:24, 85:16, 87:18, 124:23, 171:10, podhaskie's
115:6, 115:10, 97:7, 97:22, plan point
182:23 98:25, 99:1, 108:18, 182:11 police
24:19, 30:3, 100:2, 100:3, 128:17 95:5,
61:14, 104:16, 104:24, pleadings 116:15
97:25, 128:10, 144:25, 5:2, 6:19, 7:7, political 108:13, 108:17, 145:2 7:12, 18:19, 11:9 109:7, 110:16, phones 18:24, 19:15, portable
135:2, 135:17, 102:10, 102:17, 28:19, 35:2, 120:6, 153:5, 144:17, 145:15, 102:25, 103:2, 35:10, 57:21, 165:2, 166:5, 146:8, 149:21, 103:5, 128:5 60:15, 62:16, 167:10 149:24, 153:3, photo 69:23, 78:22, posed 153:17 129:2 78:23, 79:1, 112:9, 112:10
25:23, 53:4, 126:21, 127:19 96:4, 103:14, 86:12, 86:20, 53:5, 107:19, pick 106:19, 131:22, 87:8 107:24, 107:25, 141:6, 142:2, 133:17, 141:18, position
Transcript of Howan Kwok Conducted on April 1, 2021 Case 22:5007:30 - Dood30231K PFiled 03/11/02/2022113:56:16 8 dPage 78 of 92
> Transcript of Howan Kwok Conducted on April 1, 2021
53:21, 60:16, 62:8, 91:16 72:17, 79:18, 141:11, 153:14, 83:11, 85:20, presenting 90:12, 90:20, 190:6 86:22, 104:18 55:3 153:1, 162:17, profit 166:7, 166:24, possibly presently 130:15, 169:14 167:17, 83:17, 84:7, 41:2 187:4 program 12:16, privileged 154:21 preserve 21:7, 94:24, 13:8, post 162:7, 95:23, 96:1 103:8 123:18, 160:17, 163:16, 163:20, programs president 166:14, 161:14 166:20, 94:9 34:20, 175:8, posted 166:23, 167:24 175:20 progress 87:7, probably 55:6, pressed 106:11 123:10 33:1, 34:12, 87:12, promise 65:13, 65:15, 37:1, 54:2, potential 65:18 117:7 100:12, 130:18, 45:9, 45:21 pretending pronounce 151:19 potentially 54:25 8:9, 8:11, problem 158:7 173:4, 174:14 pretty 123:22, 126:22, 54:23, 137:21 power pronunciation 148:25 79:3 prevailing 9:8, 9:9, 9:10, practice proceed 172:7 178:18 8:5, 25:7, 72:4 proof prevent 84:11 prc 126:9 146:16 proceeded 149:15 previous properly 8:6 preceded 8:10, 8:11 16:18, 16:24, proceeding 49:5 136:24, 137:12, properties 5:9, 7:5, 72:6, prejudice 137:17 129:24, 130:18 72:22 172:18, 173:6, previously proposition proceedings 173:9, 174:7 7:17, 47:12, 7:1 7:23 premises 57:5, 58:4, propounded proceeds 149:12 66:10, 122:11, 142:22 159:19 preparation 153:19 proprietary produce principle 20:10, 64:6, 94:21 142:24, 144:24, 149:8 169:21 prosecuted 178:13 prepare print 13:21 12:16, produced 19:12, 20:6, 33:10, 33:13 prosecuting 135:15, 136:22, 20:15, 43:20, prior 12:25 139:8, 140:6, 63:25 48:21, 63:13, prosecution 147:17, 147:24, prepared 85:1, 67:8, 12:24 154:23, 159:24, 122:1 44:22 44:2, 120:19, protect 160:10, 160:16, preparer prison 78:19 176:25 174:18, 44:23 130:23, 131:11 protection production preparing privately 29:2, 39:21, 124:3, 124:8, 64:3, 149:12 110:7, 110:8, 67:24, 159:16 139:3, 140:7, 110:20 prescription 110:11, protections 140:10, 142:22, 15:10 privilege 28:12, 28:23, 143:23, 177:12, presence 7:10, 27:17, 74:20, 74:23 188:21 27:24, 32:3, 19:6, 25:2 protective professional 41:9, 41:12, present 127:3 2:9, 102:17, 45:14, 46:3, 3:18, 6:23, protocols 54:14 Case 22:5007:20 - DoOSIOZAK PFiled 03/11/02/2012022113:56:18 9 dPage 79 of 92
proven pursuing 159:8 52:20, 55:11, 95:9, 134:20 races 57:19, 58:20, 96:3, 114:14, 114:10 159:2 60:18, 86:14, put 87:25, 87:15, provide racism 53:1, 94:19. 88:20, 88:21, 44:19, 44:23, 123:15, 159:5 131:10, 68:17, 97:23, 99:20, 70:16, 131:11, 151:23, randazza 101:5, 101:13, 164:14, 70:19, 70:23, 164:11, 3:3, 3:8, 71:4, 73:17, 168:9, 168:15, 52:13, 104:11, 123:11, 72:2 123:16, 123:13, 183:23 rapist 114:16, 116:25, 126:6, 127:10, 128:4, 135:22, 108:1, Q 108:11, 127:12, 128:21, 139:1, 140:9, 108:18, 109:1, questioning 129:10, 129:25, 148:17 110:5, 110:8, 10:15, 88:25 132:21, 136:5, provided 110:13, 110:12, questions 143:20, 153:8, 42:16, 43:9, 110:18, 132:19, 6:14, 7:2, 154:22, 157:18, 46:7, 46:16, 134:5, 144:20, 15:6, 59:2. 157:24, 158:23, 46:25, 69:1, 151:5, 182:12 62:11, 62:14, 160:15, 161:15, 69:4, 69:16, rate 68:3, 68:7, 168:5, 169:2, 97:11, 125:11, 119:22 68:15, 68:13, 169:12, 177:10 139:24, 140:11, rather 68:18, 72:9, realtime 140:15, 143:21, 7:3, 16:3, 72:12, 77:20, 2:10, 190:7 170:12 147:6, 34:23, 34:25, 78:9, 79:21, reask public 54:14 80:1, 83:16, 33:20, 143:17 2:11, rd 83:18, 86:11, reason 82:25, 183:25, 3:13 86:14, 86:17, 11:1, 24:2, 184:1, 190:7 reach 87:23, 88:4, 60:20, 62:6, pull 172:4 88:19, 88:8, 62:9, 62:10, 121:13, 167:5 read 90:7, 118:14, 83:17, 103:17, punitive 17:6, 17:7, 126:9, 136:21, 106:12, 114:3, 132:8, 132:21, 17:20, 52:21, 143:17, 147:20, 147:14, 159:7, 133:14 52:22, 52:25, 148:2, 171:6, 168:5, 174:24, purchase 53:2, 53:4. 186:25 178:13 93:18 61:1, 89:6, quiang receive purchased 89:8, 106:2, 80:10 47:17, 51:12, 59:10, 59:12 107:4, 113:1, quick 52:8, 52:7, purported 123:16, 141:23, 59:1 52:12, 52:16, 146:4, 146:3, 141:25, 161:6, quiet 52:18, 53:5, 177:1 161:8 71:24 180:12 purpose reading quite received 26:8, 83:19, 34:12, 55:15 29:16, 100:21, 45:7, 45:18, 83:20, 131:3, ready 101:5, 113:19, 52:20, 52:24, 133:8, 156:16 65:11 143:19, 155:19, 53:4, 53:16, purposes really 168:20, 186:7, 54:6, 178:23 26:5, 26:13, 10:13, 21:12. 186:12 receivinq 26:19 27:1, 27:2, quote 53:14 pursuant 34:18, 34:22, 171:9, 171:10 recess 19:7, 22:15, 36:10, 36:18, R 66:9, 79:13. 22:19, 188:9 37:3, 37:16, race 102:8, 155:5 pursue 37:17, 37:21, 158:19, 159:4, 134:19 Transcript of Howan Kwok Conducted on April 1, 2021
Case 22:5007:30 - DoOHDZ31KPFiledQS/110/02/254EnteFieebO3/113:56:180 dPage 80 of 92
Transcript of Howan Kwok Canducted on Anril 1, 2021
recognize 38:5, 38:19, 83:12, 85:21 rephrase
158:5 41:21, 42:6, 10:11, 62:11, replace
recommended 67:17, 69:13, relied reported 16:18, 168:8 75:11, 75:20, 117:22, 183:13 1:15, 54:10, record 76:3, 76:16, remarks 130:21, 146:1
85:25, 127:13, 161:24, remember 2:10, 5:1, 5:4,
86:3, 162:18, 162:25, 18:3, 23:6, 5:13,
91:9, 163:7, 170:2, 23:13, 32:23, 58:12, 58:25, 130:1, 141:25, 171:17, 172:2, 34:5, 35:23, 80:11, 81:22,
recorded 185:11 101:20, 123:17, 141:21, 184:22, 115:8 regarding 126:4, 126:25, 190:6, 190:7
21:20, 21:22 45:21, 79:17, 147:23, 150:20, 6:9, 26:6, records 79:21, 100:13, 150:21, 153:8, 26:20, 27:7, 97:10, 127:1, 175:16, 187:3 154:5, 154:17, 27:12, 27:16, 129:17, 129:20, regards 154:21, 158:8, 27:22, 106:25, 185:20, 185:23, 130:6 169:6, 171:7, 121:5, 121:20, 185:24 registered 183:5 155:11, 155:17, recover 2:9, 180:9, remembering 155:21, 156:17, 102:10, 102:14 180:13, 190:5 116:18 171:9
102:18, 102:21, rejected 1:12, 2:8 84:6,
102:25, 120:7, 57:11 rendered representations
156:2, 163:9 relation renders represented referred 182:19 29:18, 36:17 35:5, 35:13, 16:24, 34:8 relationship renew 48:21, 62:22, referring 24:16, 82:21, 154:3 71:19, 72:22,
refers 85:10, 162:4, 93:7, 93:17 representing
refuse 169:13, 181:22, repeat 25:25, 47:21,
68:7, 68:17 relative 119:1, 127:17, 49:11, 77:18, refusing 155:17 141:18, 141:19, 77:19, 92:21
24:24, 37:12, 60:17, 72:6, repeating 25:23, 26:18
Case 22e500130-Dood50231KPFiledd3/119/02/199221137569861 dPage 81 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
57:1 50:20, 67:14, 157:2, 158:2 124:2, 124:8,
87:18, 127:2, 75:25, 76:13, 26:12 188:20
139:3, 145:23, 163:4, 181:9 ridiculous
42:18, 171:14, 171:24, 40:11, 43:8, 11:2, 17:3, 69:1, 70:16, 183:20, 185:8, 43:12, 44:2, 21:25, 26:25, 70:19, 70:23, 185:17 44:4, 44:22, 28:4, 33:18, 71:3, 73:17 responded 74:4, 181:5 35:16, 41:17,
72:24 responding 16:6, 19:16, 77:4, 79:5, requires 109:18, 171:5 20:8, 20:12, 79:7, 79:23, 71:9, 71:15 responds 25:5, 26:9, 81:1,
reservation 171:10 26:23, 28:16, 89:1,
161:10 response 28:19, 31:24, 94:4, 111:4, reserved 140:6, 142:21, 52:2, 68:23, 118:21, 125:7, 4 : 1 1 143:22, 171:3, 69:20, 69:23, 126:1, 130:9, residence 171:8 70:6, 70:10, 131:13, 132:10, 22:4, 77:4, responses 90:17, 103:15, 138:9, 142:10, 81:1 124:1, 124:7, 103:22, 104:1, 144:15, 148:3, respect 170:13, 188:18 122:7, 143:1, 152:10, 170:20, 27:23, 67:23, responsibility 144:2, 152:1, 172:8, 183:5
155:22, 162:2, responsible 165:10, 166:15, 12:9, 12:21, 162:4, 175:12 113:15, 134:25, 167:8, 167:12 24:20,
respected 135:1, 145:17, revealing 31:4,
respond 108:24, 127:24, 122:9, 152:3, 41:6,
12:8, 12:20, 134:22, 145:23, 163:16, 164:5, 42:14, 44:13,
41:6, 161:1, 161:6 40:24, 41:24, 46:21,
42:3, 42:13, restricted 42:10, 45:19, 50:6,
45:1, 53:25 46:18, 49:25 50:19, 67:15,
Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 82 of LMNOPQRSTUVTSWXYZT[\]^\_U`aObcWdTP]efOgSdhRZhRP\MiOZR\_jkR 92
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=>6?@#A@=BC <<<DEFFDFGHGIJJJD=>6?@#A@=BCD2BK Case 22:5007:30 - DoOSIOZAK PFiled 03/11/09/22/2113:56:18 3 dPage 83 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
100:23, 108:12, 105:23, 135:24, severe 93:1, 93:5, 111:3, 112:25, 177:6, 180:8, 131:5 93:8, 93:12, 114:25, 123:11, 181:23, 182:1 sexual 93:13, 93:19, sentenced 125:24, 94:4, 94:5, 124:10, 110:23, 112:2, 128:19, 130:13, 66:20 94:6, 94:12, 112:6 130:25, 132:9, 94:22, 95:6, separate shall 132:23, 133:24, 95:25, 96:23, 45:14, 79:22 4:10 134:13, 140:14, separately shares 97:19, 97:25, 142:3, 144:14, 99:2, 109:6, 143:3, 168:3 130:15. 160:1. 146:1, 149:11, 110:4, 110:7, september 160:25, 161:19 149:16, 153:15, 111:17, 112:12, 67:7, 67:8, sherry 113:12, 113:14, 179:22, 181:21, 99:10, 100:14, 22:2 183:3 113:15, 114:18, 172:13, 183:8 sherry-netherland seeing 115:1, 115:17, serious 52:14, 52:17, 124:13 116:3, 116:8, 87:15, 101:7, 55:5, 53:9, seek 129:20, 129:23, 157:18 77:4, 81:1 130:13, 130:18, 146:25, 154:3 seriously shoot 130:21, 131:12, seem 86:10, 88:9 43:6 135:17, 140:3, 32:15, 110:22, served short 144:16, 145:9, 147:23 123:3 21:13 145:15, 145:16, seems service shot 146:1, 146:7, 148:12 40:25, 42:10, 150:5 149:13, 146:9, seen 45:19, 46:18, should 149:20, 149:24, 22:21, 23:2, 66:6 15:4, 16:15, 153:18, 179:24, 32:15, 52:9, services 47:22, 54:10, 181:22, 182:4, 111:10, 122:16, 29:18, 29:25, 54:11, 62:24, 182:10, 182:18, 123:12, 133:3, 36:17, 37:19, 104:1, 106:6, 184:17, 184:20 138:23, 139:23, 47:17 111:23, 125:25, shuiyan's 177:3 session 127:12, 130:8, 77:18, 92:12, sees 62:13, 154:15 135:21, 141:11, 96:12, 96:19, 28:10 set 142:5, 145:16, 144:17, 153:17 self-incriminati-151:25, 157:19, 105:7, 124:3, sign on 161:12, 164:3, 124:8, 124:23, 24:13, 25:1, 13:4, 41:15 125:2, 188:20, 182:7 33:5, 32:20, send show 189:6, 190:11, 39:3, 33:11, 29:12, 36:16, 190:21 22:7, 60:8 91:21, 92:1, 37:14, 51:11, sets showed 126:15, 127:8, 51:14, 51:15, 105:3 89:17, 91:24, 180:23 54:2, 99:7, settled 122:11, 128:11 signature 130:23, 177:8, 172:11 showing 23:2, 23:4, 181:24 settlement 60:21 23:7, 24:3, sending shown 172:4 125:5, 125:6 61:24, 99:5 111:13, seven 19:8, signature-p1kal sends 111:21, 153:21 46:6, 46:15 190:22 56:5 shuiyan several signed sent 1:4, 78:14, 72:12, 95:1, 4:15, 4:17, 18:15, 51:13, 86:13, 87:10. 132:12, 142:18, 24:7, 32:19, 52:13, 54:17, 150:14 92:13, 92:21, PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22:5007:20-DoO516231KPFileDd3/119/2254EnteFieedO3113722113:569864 dPage 84 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
48:18 100:1, 100:14, 55:3, 84:10, 131:4, 131:20,
75:13, 107:6, 126:11, 129:4, sought spy
151:3, 151:4 149:15, 154:20, sounds ਟ ਟੈ
11:5, 40:16, 23:8 55:8, 116:15, stability
112:8, 121:10, someone 57:6, 116:19 182:5, 182:7, 133:16, 133:21, 55:15, 62:1, south 182:16 134:21, 135:6, 92:20, 107:6, 160:16, 161:13 started 136:9, 138:4, 115:1, 152:16, southern 108:12, 108:13,
166:2 somethinq 155:24, 169:24 starting simultaneously 20:2, 25:8, speak 18:16, 72:24,
65:24, 97:21, 95:16, 95:17, 138:10, 147:12, state 110:22, 116:2, 128:24, 141:10, 183:18 9:18, 10:2, 124:12, 174:6 152:18, 152:21, special 12:18, 13:21, single 165:17, 166:17, 55:9 13:23, 15:25, 169:7 166:25, 168:25 specific 32:24, 33:20, sir sometimes 102:5, 142:20 36:22, 38:22,
104:14 56:15, 56:16, 158:6, 179:6 46:8,
small 57:10, 75:1, speculation 46:17, 57:22,
social 81:20, 99:12, spell 74:5, 190:2 9:25, 11:13, 99:13, 99:14, 58:8, 58:10 state s
solemnly son 8:20, 11:10, 133:1, 133:4
20:10, 22:25, sorry 63:10, 63:13, 171:12, 171:20,
PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22:5007:20-DoO516231KPFiledd03/119/2254Enteried003113722113:569865 of 92
Transcript of Howan Kwok Conducted on April 1, 2021 submit ston
states 19:20, 72:15, 67:9, 102:16 6:19, 8:10,
10:5, 10:9, 96:4, 114:5, subscribed 58:18, 100:21, 12:18, 13:24, 131:3, 131:4, 187:11 100:22, 106:7, 14:2, 14:8, 131:19, 164:15 subsequent 111:1, 118:22, 14:12, 14:23, stopped 120:18 122:12, 122:14,
28:13, 20:2 subsequently 122:19, 123:12,
29:3, store 87:8, 146:22 123:14, 123:19,
34:14, 128:2, 128:3, substance 125:8, 127:19, 45:19, 46:8, 129:17 15:9 128:15, 139:22,
66:17, stored successfully 148:5, 148:20,
67:4, 97:4, 99:2 102:13 151:20, 165:1, 91:3, 107:18, story sue 175:18, 183:21, 183:12, 190:8 149:7, 149:8 31:19, 51:25, 186:7 stating strange 101:3, 101:14, surrounding
10:8, 10:12, 83:1, 83:2, 110:23, 173:16 187:2
11:4, 11:7, 13:7 strategy 167:1, 167:2 78:7 steel 167:9, 167:25, suggestion sussing
steve 9:16, 47:10, 3:5, 3:13 6:3, 187:11,
still 75:5, 75:10, superman 58:6, 172:21,
68:1, 68:6, 106:4, 108:24, supplement ப 68:9, 83:9, 120:2, 138:2, 70:4, 117:1 t-e-e-r 83:23, 83:25, 138:17, 141:16, support 59:3
165:16, 166:16, strongly 92:24, 93:22 61:6 170:9, 174:6 87:18, 103:21 supporters table
4:3, 4:8, 4:13 40:24, 41:11 supportive 31:19, 59:1, stipulation submissions 116:14 66:8, 84:21, 172:12, 175:3 79:16 supposed 84:24, 84:25,
PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22e500130-Dood50231KPFiledd3/119/02/119922113756g866 dPage 86 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
110:19, 120:24, 181:9 165:20, 167:3, thing
154:13, 155:3 43:21, 43:23, ten 34:18, 36:15, taken 44:9, 44:16, 15:14, 157:6, 52:20,
takes taxing ten-minute 100:23, 109:2,
13:19, 76:6 132:12, 133:13, 133:24, 135:16,
20:17, 32:1, 55:10, 81:3 41:23, 119:17, 158:25,
142:5, 144:7, 54:7 142:10, 151:3 things 155:7, 167:10 technician testified 54:2, 54:6, talked 3:19, 18:17, 6:3, 14:10, 85:11,
53:16, 101:22, 18:20, 18:24, 14:12, 14:22, 133:25, 136:16,
145:1, 145:3, 106:7, 106:9, 58:4, 66:10, 143:7,
145:10 106:18, 120:25, 84:20, 107:20, 146:13, 166:12,
16:25, 33:7, telephone 74:14, 74:17, 28:3, 32:16,
36:4, 71:22, tell 84:25, 184:4, 88:18,
55:13, 94:9 142:23, 147:4, 63:3, 176:25 87:16
38:23, 39:3, 156:11, 156:15, 22:2, 32:13, 11:17, 85:22, 39:8, 40:10, 165:16, 167:1, 180:10 94:3, 166:4 41:3, 42:10, 167:3, 172:6, thank thousand 42:17, 43:8, 174:8, 180:17, 8:19, 18:14, 142:4 43:12, 44:2, 182:8, 182:16, 19:10, 24:1, thousands 44:4, 44:22, 182:18, 182:24 75:10, 78:22, 54:16, 133:13, 44:23, 45:9, telling 89:9, 133:15, 142:12
46:7, 27:5, 33:8, 138:25, 148:22, threat 46:16, 67:10, 83:5, 92:23, 164:7, 167:19, 53:23, 53:24, 73:23, 74:1, 94:12, 95:6, 170:5, 187:5 86:20, 87:1, 74:3, 74:4, 95:8, 99:5, therefore 87:8, 87:15,
Case 22-50073 Doc 102-1 Filed 03/19/22 Entered 03/19/22 13:56:36 Page 87 of MNOPQRSTUVWUTXYZ[U\]^\_`VabPcdXeUQ^fgPhTeiS[iSQ]NjP[Z`klS 92
MNOPQRSTUVWUTXYZ[U\]^_`VabPcdXeUQ^fgPhTeiS[iSQ]NjP[Z`klS 92 Entered 03/19/22 13:56:36 Page 87 of
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?@7AB\$CB?DE ===FGHHFHI>IJKKKF?@7AB\$CB?DEF3DL Case 22:5007:30 - DoOSIOZAK PFiled 03/11/02/2012 12:56:18 88 of 92
145:11 45:12, 45:25, 70:18, 71:3, 106:16 tweeters 46:11, 46:21, 71:14, 81:12, uploading 145:19 48:12, 49:17, 90:19, 103:24, 21:15, 21:20, 67:15, 143:8, 151:23, twitter 50:6, 21:23 67:20, 74:9, 162:8, 163:13, 99:4, upper 99:7, 75:18, 76:1, 163:25, 164:19, 109:4, 110:15, 61:2 76:14, 76:24, 165:12, 165:14, 150:3, 182:10, upstairs 182:19 90:3, 91:6, 165:15, 166:21 55:2 108:22, 118:7, understood two urqa 119:10, 119:15, 62:12, 74:13, 125:15 98:3, 101:17 119:25, 120:10, uneasy 107:21, 112:3, url 120:16, 125:13, 113:7, 154:13, 86:11, 86:18, 64:22. 64:23. 126:18, 149:17, 86:24 168:12 65:2 149:22, 159:14, union two-hour use 159:22, 160:2, 154:15 190:4 9:4, 9:6, 161:22, 162:23, tycoon united 16:17, 62:2, 163:5, 169:17, 160:18 1:1, 7:24, 89:13, 98:11, 171:15, 171:25, 9:19, 10:5, U 98:14, 104:6, 181:12, 184:5, 10:9, 12:17, 104:14, 104:16, ultimately 185:9, 185:18 13:24, 14:2, 104:25, 106:17 177:11 underlying 14:8, 14:12, useful una 80:22 14:23, 27:24, 148:13 3:20 understand 28:13, 28:24, usinq unable 7:12, 6:18, 29:3, 34:13, 65:2, 98:15, 27:9, 36:5, 7:14, 7:15, 34:20, 45:19, 128:8, 134:8 36:23, 52:25, 15:6, 8:16, 46:8, 47:1, usually 82:2, 126:14 24:6, 24:10, 66:21, 67:4, 34:5, 117:19, unaccountable 24:13, 26:14, 91 : 3 117:22 150:12 26:16, 29:15, unknown V unbelievable 29:16, 52:19, 59:16 54:17, 136:16 v 67:22, 68:1, unless uncomfortable 1:6 68:6, 68:9, 6:25, 7:9, 86:10, 86:19 value 68:19, 71:8, 84:5, 154:21 under 149:5, 149:9, 73:20, 113:1, unlike 5:6, 12:9, 150:13, 151:8, 128:19, 125:12, 129:20 151:24 12:17, 12:21, 138:8, 142:1, unlock 24:21, 27:18, valued 143:6, 143:20, 60:12 27:24, 29:8, 150:22, 151:12 154:1, 155:19, until various 30:2, 30:5, 169:23, 170:1, 135:9 30:20, 31:4, 151:24, 185:2 173:25, 175:18, update 31:13, 37:6, vegas 186:7, 186:12, 69:4 37:9, 37:25, 3:6, 93:18, 186:14, 186:22, updated 38:3, 38:6, 130:14 186:23 69:16 38:13, 38:16, vehicle understanding upload 40:5, 40:19, 161:14 13:7, 16:13, 58:6, 66:5, 41:2, 41:7, vendor 28:18, 19:6, 106:5, 106:15 42:4, 42:14, 41:10, 50:10, 32:9 uploaded 44:13, 45:2, verbal 68:25, 69:7, 42:25, 58:5, 95:24, 125:10 Transcript of Howan Kwok Conducted on April 1, 2021 PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22:5007:30 - DoOSIOZAK PFiled 03/11/02/2012 12:56:18 9/12/2022 13:56:18 9 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
verbally vision wanting 65:15, 86:1, 108:16 169:20 94:4, 183:22 55:2, 133:9 weren't verification visiting warfare 85:23 32:19, 178:7 92:21, 182:4 53:25, 55:12 verified voice west warrant 83:5 22:15, 22:19, 92:14, 92:24, 14:4 188: 9 94:21, 121:9 warrants western voices 18:11 verify 14:7 whatever 94:15 112:4 washington verizon 35:23, W 91:20 47:25, 61:4 53:17, 61:22, wasting w-e-n-q-u-i 180:2 108:19, 145:17, version 16:3 8:21, 17:16, 146:10, 159:6, 17:22, way wait 177:14, 185:13 124:14 5:10, 9:15, 19:19, 102:2, via whatsapp 10:11, 51:10, 118:4, 135:9, 98:19, 177:10, 177:10, 182:2 69:7, 70:18, 136:11 182:2 vicious 71:2, 83:21, waiting 112:15, 87:13, 87:24, whatsoever 114:6, 106:14 72:6, 101:23 131:4, 131:18 108:14, 111:13, waived whereabouts 129:9, 144:24, viciously 4:7 108:15 145:6, 145:20, 137:11 wang 146:6, 153:2, whereof viciousness 91:18, 92:12, 156:8, 183:7, 190:20 112:16 92:19, 93:3, 190:18 whether video 113:11, 175:5, ways 10:21, 12:24, 21:12, 21:14, 175:15, 175:19, 166:13 23:2, 25:19, 21:16, 58:5, 175:20, 176:11, wealthy 36:10, 38:21, 64:14, 66:5, 182:2 115:17, 129:23, 41:14, 39:6, 92:6, 92:8, want 92:10, 130:2, 130:3, 44:15, 54:8, 92:15, 8:5, 8:17, 54:10, 130:22 54:9, 94:14, 99:24, 27:2, 28:7, 103:18, 128:16, wearing 54:11, 73:23, 34:19, 34:22, 75:23 85:7, 122:4, 128:23 52:19, 58:16, 122:12, 123:12, week videoconference 71:25, 85:15, 125:8, 129:14, 59:11, 3:1 59:23, 86:9, 115:25, 148:14 videos 125:22, 126:5, 138:14, 140:3, whichever 127:8 21:13, 57:18, 126:15, 145:3, 147:3, welcome 49:8 58:2, 95:22, 147:12, 148:19, whistleblower 86:3, 103:14 98:24, 99:7 149:18, 151:21, 111:5 viewers wengui 175:18, 183:1, 134:3 1:7, 22:14, white 183:21 134:17 22:25, 23:7, violation wanted whoever 121:17, 122:24, 66:22 59:1, 77:17, 47:20 virginia 123:25, 124:21, 77:23, 78:11, 160:18, 180:9, whole 168:13, 178:10, 91:21, 117:9, 188:8, 188:13, 83:16, 174:4, 179:7, 180:25, 117:23, 133:1, 188:15, 188:17, 184:17 183:11 133:4, 165:17, 189:3 virus wife 182:23 went 82:25 77:10, 77:22, 9:13, 64:20, PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM Case 22:5007:20-DoO516231KPFileDd3/119/2254EnteFieebO3412922113:56g860 dPage 90 of
78:8, 80:4, 20:1, 21:3, wrapped 170:24, 172:5,
wifi 60:10, 70:1, write 173:3, 174:14, 129:5, 129:6 70:3, 70:10, 185:1 174:22, 175:2,
willy-nilly 95:15, 96:10, 182:19 y-e-l-i-a-n-g
wind 111:20, 118:17, 38:11, 110:16, yang 118:20, 154:7, 128:14, 139:20, 110:17, 125:9, 91:18 154:9 141:15, 141:20, 135:17, 140:2, yanping window 149:19, 187:5, 171:5 175:5, 175:19 118:18, 118:20, 188:2, 190:10, wrong yeah 154:8, 154:9 190:14, 190:20 94:5, 142:10, 81:16
129:6, 176:19, 19:15 172:25, 179:16 year
wish 120:4 132:24, 144:18 42:11, 43:23, 88:13, 88:14, wonderful X 44:10, 181:6
withheld 7:3, 96:1, x-1-a-n-m-i-n 8:4, 14:20 70:14, 70:22, 122:12, 134:8, 152:23, 170:15 yingnan 73:16 134:9, 146:5 x-i-n-o 110:2, 116:9
16:11, 27:5, 23:19, 23:20, 30:14, 30:16, 31:22, 63:9, 23:21, 23:24, 151:16, 152:17
64:5, 69:10, 114:24, 115:14 32:8, 32:12, 73:8, 103:12, works 151:17, 170:15, 33:20, 38:9, 104:4, 104:19, 136:13, 167:18 170:19, 170:24,
164:20, 164:22, worry 175:2, 175:10 39:14, 39:18, 165:17, 165:20, 154:10 xino 39:24, 40:1, 167:3, 171:11, worth 170:22 40:14, 40:25,
173:9, 173:11, 150:22, 153:3, xiong 45:8, 46:8, 173:20 163:2 151:17, 152:21, 46:17, 49:22,
Case 22:5007:30 - DoOSIOZAK PFiled 03/11/2012 11:56:18 1 0 Page 91 of 92
Transcript of Howan Kwok Conducted on April 1, 2021
131:19 22 49:24, 50:3, 1 50:23, 51:1, ા ୧ 66:9 1 55:25, 56:2, 187:6 23 79:13 56:22, 18 56:25, 179:14, 188:8 1.1 63:19, 67:11, 22:2, 24 80:15, 160:18 72:1, 74:6, 171:21, 180:10 124:6, 125:24, 1.4 120:2, 120:5, 1801 126:1, 126:3 108:4 120:13, 155:24, 22:2 25 10 162:5, 168:12, 1:-cv--kpf 44:7 2:5, 23:11, 169:25, 172:21, 1:6 26.1 23:15, 24:4, 176:2, 174:17, 22:16, 22:20, 2 25:1, 65:8 180:11, 190:8 188:10 2 100 york's 2764 102:8 96:16, 124:10, 175 : 1 3:5 124:14, 151:14, 20 youtube 2nd 151:17, 152:15, 1:6, 118:14, 92:14 190:21 152:20, 152:22, 157:10, 188:7 yuan 3 161:13, 173:16 2011 96:17, 151:13 10022 184:16 30 yvette 180:11 2017 21:7, 29:5 175:5, 175:20 101 67:7, 67:8, 31 Z 107:18 91:12, 99:24, 102:8 zip 107 111:5 360803 42:25 183:11, 188:11 2018 1:17 zoom 109 92:9, 92:11, 3733 106:17 3:5 97:24, 97:25, 171:10 0 12 99:10, 99:24, 39 99:25, 66:9 100:10, 00 79:13, 155:5 100:15, 103:19, 12,000 2:5, 127:23 4 104:15, 104:17, 178:17, 178:20, 001 4 107:2, 154:18, 178:23, 179:12, 18:16 155:5 160:17, 163:10, 179:18, 180:17, 003 40 177:2, 183:7, 180:23, 181:8 120:24 102:8 122 183:8 004 42,000 2019 188:12, 188:13 121:14 183:14, 183:16. 42:11, 171:22 123 005 184:15, 184:24, 188:15 2020 124:20 185:5 23:11, 23:15, 125 006 45 24:4, 43:24, 188:17, 189:3 123:20 66:9 44:10, 172:13, 13 007 5 179:5, 179:10, 107:18 22:8 50,000 179:14, 180:8, 14 008 181: 6 132:3 154:18, 163:10 122:20 2021 510 15 05678 1:13, 2:4, 160:1, 160:24 62:12, 99:23, 1:6 125:24, 187:13, રે રે 160:17, 172:13 09 190:22 155:5 15,000 79:13 20814 114:1, 131:2, 3:14 PLANET DEPOS 888.433.3767 WWW.PLANETDEPOS.COM
DEFGHIJKLMNLKOPQRLSTUVWMXYGZ[O\LHU]^G_K\`JR`JHTEaGbJWcbJ
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