Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #1604-22

METADATA

Defendant: Guo Wengui / Miles Guo / Ho Wan Kwok
Court: CTB
Case No.: 22-50073
ECF #: 1604
Type: EXHIBIT
Filed: 2023-03-27

FULL TEXT

#### **Exhibit 22**

| | UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT | |---------------------------------|-----------------------------------------------------------------------------------------------------------------------------------| | In Re | * Chapter 11 * * | | HO WAN KWOK, | * Case 22-50073(JAM) | | Debtor. | * * * | | * * * * * * * * * * * * * * * * | | | | TRANSCRIPT OF CONTINUED | | | 341 MEETING OF CREDITORS | | | APRIL 6, 2022 | | | Electronically Recorded by the Office of the United States Trustee | | | Transcript Prepared By: | | Shelton, CT | Christine Fiore, CERT Fiore Reporting and Transcription Service, Inc. 4 Research Drive, Suite 402 06484 (203)929-9992 | | | |

| Case 22-50073 Doc 1604-22 | Filed 03/27/23 134 | Entered 03/27/23 14:12:10 | Page 3 of | |----------------------------------------------------------|-----------------------------|-----------------------------------------------------------------------------------------------------------------------------------|-----------| | | Ho Wan Kwok - April 6, 2022 | | | | APPEARANCES: | | | | | For the Debtor: | | WILLIAM R. BALDIGA, ESQ. BEN SILVERBERG, ESQ. Brown Rudnick, LLP Seven Times Square New York, NY 10036 | | | For the U.S. Trustee: | | HOLLEY E. CLAIBORN, ESQ. STEVEN MACKEY, ESQ. Office of the U.S. Trustee 150 State Street New Haven, CT 06510 | | | For Logan Cheng, Creditor: | | JAY MARSHALL WOLMAN, ESQ. Randazza Legal Group 100 Pearl Street, 14th Floor Hartford, CT 06103 | | | For Pacific Alliance LP, Creditors: | Asia Opportunity Fund, | DAVID V. HARBACH, II, ESQ. O'Melveny & Myers, LLP 1625 I Street NW Washington, DC 20006 | | | | | STUART SARNOFF, ESQ. MAKENZIE RUSSO O'Melveny & Myers, LLP Times Square Tower 7 Times Square New York, NY 10036 | | | | | ANNECCA SMITH, ESQ. Robinson and Cole 280 Trumbull Street Hartford, CT 06103 | | | For Bruno Wu, Weican Meng and Rui Ma, Creditors: | | KRISTEN MAYHEW, ESQ. McElroy, Deutsch, Mulvaney & Carpenter One State Street Hartford, CT 06103 | | | For the Official Committee of Unsecured Creditors: | | STEVEN STAFSTROM, ESQ. Pullman & Comley 850 Main Street Bridgeport, CT 06601 | |

Ho Wan Kwok - April 6, 2022

| 1 | MS. CLAIBORN: Good morning. Today is | |----|--------------------------------------------------------| | 2 | Wednesday, April 6th, 2022. We are gathered for the | | 3 | continued meeting of creditors in the Chapter 11 | | 4 | case of Ho Wan Kwok, case no. 22-50073. | | 5 | My name is Holley Claiborn. I'm a trial | | 6 | attorney in the Office of the United States Trustee | | 7 | and I will be conducting today's meeting. Today's | | 8 | meeting is being recorded on a digital recorder and | | 9 | is also available for parties to participate on the | | 10 | phone. And there are parties, including the debtor | | 11 | and counsel and other professionals, gathered here | | 12 | in person. | | 13 | Today's meeting is being interpreted, as | | 14 | you can hear and our interpreter today is Jeff and | | 15 | I'm going to ask Jeff to respond to this oath. | | 16 | (The interpreter is sworn.) | | 17 | THE COURT: On behalf of Mr. Kwok we have | | 18 | William Baldiga and Ben Silverberg. | | 19 | Also on behalf of the debtor we have | | 20 | financial professionals Craig Gelbert and Matthew | | 21 | Flynn. | | 22 | Present here today on behalf of the | | 23 | Committee of Unsecured Creditors is Steven Stafstrom | | 24 | from Pullman and Comley. |

| | Ho Wan Kwok - April 6, 2022 4 | |----|----------------------------------------------------| | 1 | Mr. Stafstrom is the lawyer for the | | 2 | Official Committee of Unsecured Creditors. | | 3 | Also present today on behalf of PAACS | | 4 | Stuart Sarnoff, David Harbach and MacKenzie Russo. | | 5 | They represent PAACS. | | 6 | On behalf of certain creditors, including | | 7 | Rui Ma, we have Kristen Mayhew. | | 8 | On behalf of creditor, Logan Cheng, we | | 9 | have Jay Wolman. | | 10 | Also on behalf of PAACS we have Annecca | | 11 | Smith, from Robinson and Cole. | | 12 | And then also for the debtor today we have | | 13 | Josh Klein and Aaron Mitchell. | | 14 | Today's meeting will feature me asking | | 15 | questions first, followed by the opportunity for | | 16 | creditors to come up and ask questions. | | 17 | Is anyone on the telephone conference | | 18 | line? | | 19 | MR. MACKEY: Steven Mackey from the U.S. | | 20 | Trustee's Office is on the conference line. | | 21 | Thank you, Mr. Mackey. Anyone else | | 22 | besides Mr. Mackey. | | 23 | Hearing none, I'm going to proceed to | | 24 | swearing in Mr. Kwok. | | 25 | (The debtor is sworn.) |

Ho Wan Kwok - April 6, 2022

| 1 | MS. CLAIBORN: Mr. Kwok, as you know, | |----|------------------------------------------------------| | 2 | today's meeting is being recorded and Mr. Jeff here | | 3 | is our official interpreter for today. | | 4 | Jeff will be interpreting the questions | | 5 | that I ask and your answers, and I ask that you wait | | 6 | until Jeff has made a full translation before you | | 7 | answer my questions. | | 8 | EXAMINATION BY MS. CLAIBORN: | | 9 | Q Mr. Kwok, we're going to pick up today in | | 10 | an area that we left off in general from the last | | 11 | meeting of creditors that was held back on March | | 12 | 21st, 2022. | | 13 | Has anything changed in your employment | | 14 | status since March 21st, 2022? | | 15 | A No. | | 16 | Q Has anything changed with respect to your | | 17 | residence? | | 18 | A No. | | 19 | Q During the meeting held on March 21st, | | 20 | 2022 I asked you about the accuracy of your | | 21 | bankruptcy schedules and your bankruptcy statement | | 22 | of financial affairs. | | 23 | A No change. | | 24 | Q Thank you. | | 25 | MS. CLAIBORN: Jeff, for purposes of my |

| | Ho Wan Kwok - April 6, 2022 6 | |----|--------------------------------------------------------| | 1 | questions I'm going to be following the documents | | 2 | that are in front of you. When I say schedules, it's | | 3 | this document. And then this document is the | | 4 | statement of financial affairs. Okay? And when I | | 5 | refer to an ECF number, it's at the top of the page. | | 6 | THE OFFICIAL INTERPRETER: ECF number. | | 7 | Okay. | | 8 | MS. CLAIBORN: Okay? That should allow | | 9 | you to follow along and start on this page. | | 10 | EXAMINATION BY MS. CLAIBORN: | | 11 | Q Okay. Mr. Kwok, I'm going to ask you to | | 12 | make sure you have in front of you, which you appear | | 13 | to do, Schedules A-B through J. | | 14 | THE PRIVATE INTERPRETER: He has Mandarin | | 15 | translations in front of him. | | 16 | BY MS. CLAIBORN: | | 17 | Q I see that Mr. Baldiga, who is seated next | | 18 | to you, has English versions. But in front of you, | | 19 | Mr. Kwok, appear to be translations. Is that | | 20 | accurate? | | 21 | A Just on Schedule A-B. | | 22 | Q Okay. So, Mr. Kwok, when you're answering | | 23 | my questions today, you're going to be taking a look | | 24 | at your own translated versions of the bankruptcy | | 25 | schedules. |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 8 of 134 | |---------------|--------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 7 | | 1 | A Okay. | | 2 | Q Okay. | | 3 | THE PRIVATE INTERPRETER: Just a minute, | | 4 | Your Honor. | | 5 | MS. CLAIBORN: Yes. | | 6 | THE PRIVATE INTERPRETER: I'm having a | | 7 | little difficulty hearing the interpreter when he | | 8 | interprets the witness's answers. | | 9 | MS. CLAIBORN: Okay. So, Jack, if you | | 10 | could speak up. I'm going to move the microphone. | | 11 | THE OFFICIAL INTERPRETER: Oh, okay. | | 12 | MS. CLAIBORN: See if that works. | | 13 | BY MS. CLAIBORN: | | 14 | Q Okay. Mr. Kwok, starting at Question No. | | 15 | 1 on Schedule A-B. With respect to Schedule A-B at | | 16 | Question No. 1, that asks if you own any legal or | | 17 | equitable interest in any real estate residence or | | 18 | building or similar property. Your answer to that | | 19 | Question No. 1 was no, Mr. Kwok. Is that an | | 20 | accurate answer? | | 21 | A Yes. | | 22 | Q Mr. Kwok, have you owned any real estate | | 23 | between the year 2018 and your bankruptcy filing in | | 24 | February of 2022? | | 25 | THE OFFICIAL INTERPRETER: Can you repeat |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 | Entered 03/27/23 14:12:10 | Page 9 of | |---------------|-------------|----------------|---------------------------|-----------| |---------------|-------------|----------------|---------------------------|-----------|

| | Ho Wan Kwok - April 6, 2022 8 | |----|------------------------------------------------------| | 1 | that one? | | 2 | BY MS. CLAIBORN: | | 3 | Q Have you owned any real estate between the | | 4 | year 2018 and your bankruptcy filing in February | | 5 | 2022? | | 6 | THE OFFICIAL INTERPRETER: Can you repeat | | 7 | that one? He said he didn't hear that. | | 8 | BY MS. CLAIBORN: | | 9 | Q Mr. Kwok -- | | 10 | MR. BALDIGA: I'm sorry. I couldn't hear. | | 11 | THE OFFICIAL INTERPRETER: He said that he | | 12 | didn't understand the translation. I just want to | | 13 | make sure I understand first. | | 14 | MS. CLAIBORN: I'll repeat the question. | | 15 | THE OFFICIAL INTERPRETER: Yes. | | 16 | BY MS. CLAIBORN: | | 17 | Q Mr. Kwok, have you owned any real estate | | 18 | between 2018 and February of 2022? | | 19 | A No. | | 20 | Q Mr. Kwok, as of the bankruptcy filing in | | 21 | February 2022, did you have any equitable interest | | 22 | in any real estate anywhere in the world? | | 23 | A No. | | 24 | Q Mr. Kwok, as of the bankruptcy filing in | | 25 | February 2022, did you have any legal interest in |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 10 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 9 | | 1 | any real estate anywhere in the world? | | 2 | A No. | | 3 | Q Mr. Kwok, have you ever owned any real | | 4 | estate in Hong Kong? | | 5 | A No. | | 6 | THE PRIVATE INTERPRETER: What was the | | 7 | answer? | | 8 | THE OFFICIAL INTERPRETER: No. | | 9 | BY MS. CLAIBORN: | | 10 | Q Mr. Kwok, have you ever owned the property | | 11 | located at 16A South Bay Road, Hong Kong? | | 12 | A No. | | 13 | Q Mr. Kwok, do you currently own an | | 14 | apartment at the Sherry Netherland in New York City? | | 15 | THE OFFICIAL INTERPRETER: I didn't get | | 16 | it. Can I ask him repeat the -- repeat the answer? | | 17 | MR. BALDIGA: You have to say -- whatever | | 18 | you're going to say, you have to -- you're talking | | 19 | to everybody, not just Holley, so I need to hear | | 20 | what you're saying. | | 21 | THE OFFICIAL INTERPRETER: Okay. I just - | | 22 | - I just want to ask him to repeat -- repeat the | | 23 | answer. | | 24 | MR. BALDIGA: Okay. | | 25 | THE OFFICIAL INTERPRETER: Okay? |

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| Ho Wan Kwok - April 6, 2022 | | |-----------------------------|--| |-----------------------------|--|

| 1 | THE WITNESS: I don't own that real estate | |----|--------------------------------------------------------| | 2 | in New York, the Sharon -- the Sharons -- at that | | 3 | address I don't remember, and I own -- I own 50 | | 4 | percent the stock -- the stock and -- | | 5 | THE PRIVATE INTERPRETER: No. | | 6 | THE OFFICIAL INTERPRETER: No? | | 7 | THE PRIVATE INTERPRETER: No. | | 8 | THE OFFICIAL INTERPRETER: Okay. | | 9 | THE WITNESS: For the family. | | 10 | MS. CLAIBORN: Can I ask you not to | | 11 | interrupt? Can you just wait until the end and then | | 12 | -- | | 13 | THE PRIVATE INTERPRETER: Okay. | | 14 | MS. CLAIBORN: -- you can express whatever | | 15 | it is you want to say? | | 16 | THE PRIVATE INTERPRETER: Okay. | | 17 | MS. CLAIBORN: Can you please just | | 18 | translate Mr. Kwok's answer again? | | 19 | THE OFFICIAL INTERPRETER: Yeah. I just | | 20 | want to repeat, make sure -- and I said it right, | | 21 | you know, what he said. | | 22 | THE WITNESS: So, yeah, he -- he said, I | | 23 | owe -- I own 50 percent of the -- 50 percent, but I | | 24 | don't own the whole real estate, but I just | | 25 | represent the family. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 | Entered 03/27/23 14:12:10 | Page 12 | |---------------|-------------|----------------|---------------------------|---------| |---------------|-------------|----------------|---------------------------|---------|

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| | 11 | |--|----| | | |

| 1 | BY MS. CLAIBORN: | |----|---------------------------------------------------------| | 2 | Q Mr. Kwok, what do you own 50 percent of? | | 3 | A Bravo Luck, 50 percent of the stock powder | | 4 | -- power. I don't know. I don't understand. | | 5 | THE PRIVATE INTERPRETER: (Indiscernible.) | | 6 | THE OFFICIAL INTERPRETER: He owned -- he | | 7 | said he owns the 50 percent of it. | | 8 | THE PRIVATE INTERPRETER: -- we can hear | | 9 | you fine, Holley. | | 10 | MS. CLAIBORN: Okay. I'm going to ask -- | | 11 | I'm going to -- | | 12 | THE PRIVATE INTERPRETER: I don't know if | | 13 | the microphone is connected to anything. | | 14 | MS. CLAIBORN: It is. It is. Jeff, if | | 15 | you can speak up? | | 16 | THE OFFICIAL INTERPRETER: Mr. Kwok said | | 17 | he owe -- he owns 50 percent of -- of the stock. Is | | 18 | it like the stock of the real estate or something? | | 19 | I don't know. I don't get it. But you can help if | | 20 | she wants to help. Do you want him to help a little | | 21 | bit? | | 22 | MS. CLAIBORN: I'd rather not. | | 23 | THE OFFICIAL INTERPRETER: Okay. | | 24 | MS. CLAIBORN: So, I'll just -- I'll ask | | 25 | follow-up questions. |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 13 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 12 | | 1 | THE OFFICIAL INTERPRETER: Okay. | | 2 | MR. BALDIGA: All right. But I need to | | 3 | hear if it's a misinterpretation, so -- | | 4 | MS. CLAIBORN: I'm going to ask a | | 5 | clarifying question, if I could. | | 6 | BY MS. CLAIBORN: | | 7 | Q Mr. Kwok, do you own 50 percent of a | | 8 | company called Bravo Luck? | | 9 | A I represent my family to hold 50 percent | | 10 | of the stock. | | 11 | Q Mr. Kwok, when you use the term -- | | 12 | MR. BALDIGA: Could I hear that back? | | 13 | Could you repeat that? | | 14 | THE OFFICIAL INTERPRETER: Yeah. I | | 15 | represent my family to hold 50 percent of the stock | | 16 | of the -- of the company. | | 17 | MR. BALDIGA: Okay. | | 18 | BY MS. CLAIBORN: | | 19 | Q Mr. Kwok, when you say family, what do you | | 20 | mean? | | 21 | A My family is a big family and that | | 22 | includes a lot of people. My kids and my sister-in | | 23 | laws, and all people together. A lot of people. | | 24 | Q Mr. Kwok, who owns an interest -- | | 25 | MR. BALDIGA: Excuse me. We do have an |

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| | Ho Wan Kwok - April 6, 2022 13 | |----|------------------------------------------------------| | 1 | interpretation question. | | 2 | THE PRIVATE INTERPRETER: I just want to | | 3 | ask that, is there supposed to be summary of the | | 4 | (indiscernible) the interpretation? | | 5 | MS. CLAIBORN: To the best of Mr. Jeff's | | 6 | ability, it should be verbatim. | | 7 | THE PRIVATE INTERPRETER: Right. So if | | 8 | Mr. Kwok said, my son, my daughter, my brother, my | | 9 | sister-in-law, my nephew, my niece, many people, | | 10 | then if the interpreter say, well, a lot of my | | 11 | families and my brother, many people, then should it | | 12 | be correct or not? | | 13 | MS. CLAIBORN: I would prefer that Mr. | | 14 | Jeff translate as literally as possible. So with | | 15 | that instruction, can we -- | | 16 | THE OFFICIAL INTERPRETER: Yeah. | | 17 | MS. CLAIBORN: -- do a specific job as | | 18 | best we can going forward? Thank you. | | 19 | MR. BALDIGA: Thank you. | | 20 | BY MS. CLAIBORN: | | 21 | Q So, Mr. Kwok, who owns the company called | | 22 | Bravo Luck? | | 23 | A My son. | | 24 | Q And what is your son's name? | | 25 | A Cheng Wu. |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 15 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 14 | | 1 | Q How long has your son owned Bravo Luck? | | 2 | A I don't remember. | | 3 | THE PRIVATE INTERPRETER: Say again, | | 4 | please. | | 5 | THE OFFICIAL INTERPRETER: I don't | | 6 | remember. | | 7 | BY MS. CLAIBORN: | | 8 | Q So, Mr. Kwok, what do you own 50 percent | | 9 | of when you explained your ownership interest in the | | 10 | Southern Sherry Netherland? | | 11 | MR. BALDIGA: Objection. You may | | 12 | interpret. | | 13 | THE OFFICIAL INTERPRETER: Can you repeat | | 14 | that one again, Holley? | | 15 | BY MS. CLAIBORN: | | 16 | Q Mr. Kwok, you testified that you owned 50 | | 17 | percent of some company, and that was in response to | | 18 | my question if you owned the Sherry Netherland | | 19 | apartment. Can you please explain what you meant? | | 20 | A Sherry is a co-op. It doesn't have the -- | | 21 | it doesn't have the -- it doesn't have the | | 22 | ownership. | | 23 | THE PRIVATE INTERPRETER: May I, Ms. | | 24 | Holley? | | 25 | MR. BALDIGA: Yes, of course. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 | Entered 03/27/23 14:12:10 | Page 16 | |---------------|-------------|----------------|---------------------------|---------| |---------------|-------------|----------------|---------------------------|---------|

| | Ho Wan Kwok - April 6, 2022 15 | |----|-------------------------------------------------------| | 1 | THE PRIVATE INTERPRETER: You've got to | | 2 | speak louder. | | 3 | MS. CLAIBORN: Okay. I'm going to put | | 4 | ourselves on pause for a second here. | | 5 | (Off the record) | | 6 | MS. CLAIBORN: All right. We're back on | | 7 | the record after a short break, and, Mr. Kwok, you | | 8 | remain under oath. | | 9 | Jeff, could you please retranslate? | | 10 | THE OFFICIAL INTERPRETER: Yeah. | | 11 | MS. CLAIBORN: The last question. You | | 12 | want me to ask it again? | | 13 | THE OFFICIAL INTERPRETER: Yeah. Would | | 14 | you ask it again? | | 15 | MS. CLAIBORN: All right. I'll try it | | 16 | again. | | 17 | BY MS. CLAIBORN: | | 18 | Q Mr. Kwok, you testified today that you own | | 19 | 50 percent of an interest in some company, and that | | 20 | was the answer you gave me in response to my | | 21 | question if you own an apartment at the Sherry | | 22 | Netherland. Can you please explain your answer? | | 23 | MR. BALDIGA: Objection. | | 24 | THE WITNESS: I don't know how to explain | | 25 | it. He said the Sherry Netherland is a co-op. I |

Ho Wan Kwok - April 6, 2022 of 134

| 1 | don't have a deed on that property and I just | |----|------------------------------------------------------| | 2 | represent my family to own 50 percent of the right. | | 3 | MR. BALDIGA: Excuse me. Go ahead. | | 4 | THE PRIVATE INTERPRETER: Because that -- | | 5 | Mr. Kwok did mention the company name Bravo Luck, so | | 6 | Mr. Interpreter did not say the word Bravo Luck, the | | 7 | company that holds the interest of Sherry | | 8 | Netherland, and Mr. Kwok represents the family owns | | 9 | 50 percent of Bravo Luck, which is the holding | | 10 | company of owning the Sherry Netherland. The Sherry | | 11 | Netherland is a co-op. | | 12 | MR. BALDIGA: So I'm going to make a | | 13 | continuing objection to the extent that the | | 14 | interpreter is not providing the exact words used by | | 15 | the witness. I'm not ascribing any faults or | | 16 | anything, but obviously that's critical to the | | 17 | quality of the testimony and that's necessary. | | 18 | MS. CLAIBORN: We need -- | | 19 | MR. BALDIGA: We have to use the words | | 20 | used by the witness. | | 21 | MS. CLAIBORN: I'm sure that Jeff is going | | 22 | to do his best job today to try to translate | | 23 | everything literally. | | 24 | MR. BALDIGA: Thank you. | | 25 | MS. CLAIBORN: But please understand that |

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| Ho Wan Kwok - April 6, 2022 | | | | |-----------------------------|--|--|--| |-----------------------------|--|--|--|

| 1 | there is a familiarity with terms in this room that | |----|-----------------------------------------------------| | 2 | Mr. Jeff does not have. So to the extent that | | 3 | people are answering questions with shorthand | | 4 | versions of company names or just one words, the | | 5 | answer should be as specific as possible -- | | 6 | THE OFFICIAL INTERPRETER: Yeah, I -- | | 7 | MS. CLAIBORN: -- if you could translate | | 8 | that. | | 9 | THE OFFICIAL INTERPRETER: -- my best but | | 10 | probably that interpreter honestly, Holley, the | | 11 | interpreter probably know the case more, the | | 12 | details. | | 13 | MS. CLAIBORN: I agree. Can you just -- | | 14 | THE OFFICIAL INTERPRETER: But if he -- | | 15 | MS. CLAIBORN: -- can you translate what I | | 16 | just said to Mr. Kwok, because I want to make sure | | 17 | -- | | 18 | THE OFFICIAL INTERPRETER: Oh. | | 19 | MS. CLAIBORN: -- he answers questions in | | 20 | a way that are easily translatable. | | 21 | THE OFFICIAL INTERPRETER: I just tell him | | 22 | and the answer let -- you know short and clear, but | | 23 | I pretty much understand what he says and -- | | 24 | MS. CLAIBORN: And can you please | | 25 | translate Mr. Kwok's answers or comments to your |

Ho Wan Kwok - April 6, 2022 of 134

| 1 | comments? | |----|------------------------------------------------------| | 2 | THE OFFICIAL INTERPRETER: He said he will | | 3 | try to make it a shorter and clear and -- but he | | 4 | needs to explain the details as much as he can | | 5 | because it's a -- it's related to his lifeline. | | 6 | MS. CLAIBORN: Mr. Sarnoff? | | 7 | MR. SARNOFF: Yeah. I just wanted to make | | 8 | clear that to the extent there is a discrepancy | | 9 | between the interpreter -- the translator, the | | 10 | official translator and Mr. Kwok's interpreter, that | | 11 | the translator is the final arbiter and that unless | | 12 | the translator agrees with the translation | | 13 | difference that the interpreter is putting forth, | | 14 | they have to work that out before we can defer to | | 15 | the -- to Mr. Kwok's personal interpreter as what | | 16 | Mr. Kwok said. | | 17 | MR. BALDIGA: I don't accept that. | | 18 | MR. SARNOFF: That's fine. | | 19 | MR. BALDIGA: That can be your position. | | 20 | MR. SARNOFF: Okay. The position has to | | 21 | be that the translator has to agree with the | | 22 | interpreter about what Mr. Kwok said for the record | | 23 | to be accurate. | | 24 | MR. BALDIGA: That -- I understand your | | 25 | position. |

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| 1 | THE OFFICIAL INTERPRETER: So, Holley, if | |----|------------------------------------------------------| | 2 | I miss anything that his personal interpreter wants | | 3 | to make up whatever I'm missing, some of the detail | | 4 | information, and is it okay for her to add on and if | | 5 | I agree what -- you know, what I'm missing or what | | 6 | he said, maybe I'm missing some detail information | | 7 | and some -- | | 8 | MS. CLAIBORN: I think the better route | | 9 | for today -- | | 10 | THE OFFICIAL INTERPRETER: Yeah. | | 11 | MS. CLAIBORN: -- and for purposes of a | | 12 | clear translation and a clear record -- | | 13 | THE OFFICIAL INTERPRETER: Okay. | | 14 | MS. CLAIBORN: -- is for you, Jeff, to | | 15 | interpret -- | | 16 | THE OFFICIAL INTERPRETER: Uh-huh. | | 17 | MS. CLAIBORN: -- my questions and to | | 18 | interpret Mr. Kwok's answers. | | 19 | THE OFFICIAL INTERPRETER: Okay. | | 20 | MS. CLAIBORN: And if Mr. Kwok thinks, | | 21 | based on your interpretation, that you have not | | 22 | translated properly, then he can testify again and | | 23 | you can try again. | | 24 | But I would like to restrict the | | 25 | interaction that happens between translators and |

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| 1 | between Mr. Kwok's personal translator so that we | |----|--------------------------------------------------------| | 2 | have an official record where the person asking the | | 3 | question is me, it's being officially translated, | | 4 | and Mr. Kwok is giving the answers, and that also is | | 5 | being officially translated. | | 6 | MR. BALDIGA: But, Holley, the problem | | 7 | with that is the witness doesn't know whether Jeff's | | 8 | English report is in fact accurate. You can't leave | | 9 | it up to the witness. That's why we have a check | | 10 | interpreter. If he spoke English, then we wouldn't | | 11 | need any interpreters. He can't do that. | | 12 | MS. CLAIBORN: I think as a practical | | 13 | matter, Mr. Kwok speaks enough English to know | | 14 | whether or not he's answered his question. | | 15 | MR. BALDIGA: No, he doesn't. I object. | | 16 | MS. CLAIBORN: Well, I -- I think that | | 17 | that has been what I have seen from my own personal | | 18 | experience. | | 19 | That said, we're going to try and do the | | 20 | best we can -- | | 21 | MR. BALDIGA: I agree. | | 22 | MS. CLAIBORN: -- and we'll see where we | | 23 | go. | | 24 | MR. BALDIGA: Okay. | | 25 | MS. CLAIBORN: Okay? |

| Case 22-50073 | Doc 1604-22 |---------------| | | | 1 | 2 | Q | 3 | | 4 | 5 | A | 6 | | 7 | 8 | Q | 9 | | 10 | A | 11 | Q | 12 | | 13 | 14 | | 15 | 16 | | 17 | | 18 | | 19 | | 20 | | 21 | | 22 | 23 | | 24 | | 25 | | Filed 03/27/23 of 134 | Entered 03/27/23 14:12:10 | Page 22 | -----------------------|-----------------------------|------------------------------------------------------|---------| | Ho Wan Kwok - April 6, 2022 | | 21 | | BY MS. CLAIBORN: | | | | | | So back to questions and answers. | Mr. | | | Kwok, do you own an interest in Genever Holdings | | | Corporation? | | | | | | I just have -- in reality, I don't, but I | | | | just held -- I just represent my family to hold some | | | interest. | | | | | | Is anyone authorized to act on behalf of | | | | Genever Holdings Corporation aside from you? | | | My son. | | | | | Is there a document that memorializes your | | | | ownership interest, whatever it is, in Genever | | | Holdings Corporation? | | | | | MR. BALDIGA: | Objection. You -- you may | | | answer. | | | | | THE WITNESS: | No. | | | THE PRIVATE INTERPRETER: | Ms. Holley, can | | | | I -- first of all, the last time that -- when he was | | | | saying -- instructing the witness about his | | | | testimony, what should it be, I don't think the | | | | interpreter -- the official interpreter interpreted | | | your instruction. | | He is telling the witness what he | | | | should be doing, but not what you were saying. | | | | And then, now that the witness is saying | | | | that he asked the interpreter twice that -- you were | |

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| 1 | talking about ownership, you were talking about | |----|--------------------------------------------------------| | 2 | ownership interest. Now he used twice these words, | | 3 | and then at the end, Mr. Jeff said, yes. And then, | | 4 | so he answered no, but then the interaction was not | | 5 | interpreted. | | 6 | MS. CLAIBORN: Mr. Jeff, could you | | 7 | translate? | | 8 | THE OFFICIAL INTERPRETER: I don't know | | 9 | what she just said. I don't know. I didn't | | 10 | understand what she's saying. | | 11 | THE PRIVATE INTERPRETER: I mean, every | | 12 | word should be interpreted. The witness -- every | | 13 | word the witness says should be interpreted. Ms. | | 14 | Holley's words should be interpreted, right? | | 15 | MS. CLAIBORN: Yes. | | 16 | THE PRIVATE INTERPRETER: Right. But he | | 17 | will -- not interpreted Ms. Holley's -- and you did | | 18 | not interpret everything Mr. Kwok said. | | 19 | THE OFFICIAL INTERPRETER: Okay. Maybe -- | | 20 | maybe we should have her to interpret. I'm going to | | 21 | excuse myself. I don't know -- | | 22 | MS. CLAIBORN: I'm going to put the -- | | 23 | THE OFFICIAL INTERPRETER: -- I'm not | | 24 | familiar with -- | | 25 | MS. CLAIBORN: -- I'm going to put the |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 | Entered 03/27/23 14:12:10 | Page 24 | |---------------|-------------|----------------|---------------------------|---------| | | | | | |

| | Ho Wan Kwok - April 6, 2022 23 | |----|----------------------------------------------------| | 1 | matter on pause for a moment. | | 2 | THE OFFICIAL INTERPRETER: Yeah, yeah, | | 3 | yeah. | | 4 | (Off the record) | | 5 | MS. CLAIBORN: All right. We are back on | | 6 | the record after a short break. | | 7 | Mr. Kwok, you remain under oath. | | 8 | BY MS. CLAIBORN: | | 9 | Q Mr. Kwok, do you have any United States | | 10 | currency with you today? | | 11 | A No. | | 12 | Q When you filed your bankruptcy case, did | | 13 | you have any United States currency? | | 14 | A No. | | 15 | Q Mr. Kwok, do you own any foreign currency? | | 16 | A No. | | 17 | Q Mr. Kwok, do you own any digital currency? | | 18 | A No. | | 19 | Q Mr. Kwok, do you have any financial | | 20 | accounts of any kind in the United States? | | 21 | A No. | | 22 | Q Mr. Kwok, do you have any financial | | 23 | accounts of any kind outside of the United States? | | 24 | A No. | | 25 | Q On March 21st, you testified you have no |

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| | Ho Wan Kwok - April 6, 2022 | |----|---------------------------------------------------| | 1 | job and no source of income. Who pays for your | | 2 | household expenses? | | 3 | A Sometimes my son, sometimes my wife, or | | 4 | sometimes my other family member. | | 5 | Q Do you have access to any credit cards? | | 6 | A No. | | 7 | Q Do you have access to any debit cards | | 8 | attached to a bank account? | | 9 | A No. | | 10 | Q How do you pay for groceries? | | 11 | A My son, my wife, my family members' | | 12 | company pay for. | | 13 | Q Where does your son live? | | 14 | A London. | | 15 | Q How does your son send you money? | | 16 | A He has a family office in a company, New | | 17 | York. | | 18 | Q Does the family office give you money? | | 19 | A They pay the expenses above. | | 20 | Q What does the term family office mean? | | 21 | MR. BALDIGA: Objection. You may answer. | | 22 | THE OFFICIAL INTERPRETER: Can I ask to -- | | 23 | ask him to repeat? | | 24 | MS. CLAIBORN: Yes. | | 25 | THE OFFICIAL INTERPRETER: Okay. Can you |

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| 1 | -- | |----|--------------------------------------------------------| | 2 | MR. BALDIGA: Right. He also have to | | 3 | interpret for the witness what I say. | | 4 | MS. CLAIBORN: You haven't said anything | | 5 | yet and he's going to ask him to repeat his answers | | 6 | so then he's going to translate, and then we can | | 7 | have whatever discussion you want to have. | | 8 | THE PRIVATE INTERPRETER: The counsel | | 9 | raised objection. The interpreter did not interpret | | 10 | the objection. | | 11 | MS. CLAIBORN: I can happily repeat the | | 12 | question, but we are not going to get anywhere today | | 13 | in a meaningful fashion if people are interrupting | | 14 | on basic questions. | | 15 | MR. BALDIGA: No, I didn't interrupt, but | | 16 | -- | | 17 | MS. CLAIBORN: So let me try again. | | 18 | MR. BALDIGA: Okay. But hold on. If I | | 19 | object or if I say anything else, that has to be | | 20 | interpreted. | | 21 | MS. CLAIBORN: You're not waiting for | | 22 | space to interpret. So, Mr. Jeff, can you interpret | | 23 | that exchange that just happened? | | 24 | THE OFFICIAL INTERPRETER: Okay. I don't | | 25 | know. It's just too much interruption. |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 27 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 26 | | 1 | MS. CLAIBORN: Right. | | 2 | THE OFFICIAL INTERPRETER: Holley, I can't | | 3 | do -- keep doing this. I just too distracted and I | | 4 | don't know. It just a simple -- ask the witness | | 5 | just a simple repeat and then -- | | 6 | MS. CLAIBORN: Let me try -- | | 7 | THE OFFICIAL INTERPRETER: -- it gets all | | 8 | these people involved. | | 9 | MS. CLAIBORN: Correct. Let me -- | | 10 | THE OFFICIAL INTERPRETER: We're not going | | 11 | anywhere. | | 12 | MS. CLAIBORN: Let me try the question | | 13 | again. | | 14 | BY MS. CLAIBORN: | | 15 | Q Mr. Kwok, what do you mean by the term, | | 16 | family office? | | 17 | MR. BALDIGA: Objection. You may answer. | | 18 | MS. CLAIBORN: Mr. Baldiga, that term is | | 19 | all over the papers. Can you repeat -- translate? | | 20 | THE OFFICIAL INTERPRETER: No, I'm not | | 21 | going anywhere. Holley, I just excuse myself. I'm | | 22 | sorry. It's -- it's not going -- | | 23 | MS. CLAIBORN: I'm going to put it on | | 24 | pause, please. | | 25 | THE OFFICIAL INTERPRETER: -- this is too |

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| | Ho Wan Kwok - April 6, 2022 27 | |----|------------------------------------------------------| | 1 | much. | | 2 | (Off the record) | | 3 | MS. CLAIBORN: We're back on the record | | 4 | after a short break. | | 5 | Mr. Kwok, you remain under oath. During | | 6 | the break, I spoke with Attorney Baldiga and we have | | 7 | agreed that all objections as to form of the | | 8 | question are reserved. | | 9 | I'm going to go back to my questions. | | 10 | BY MS. CLAIBORN: | | 11 | Q The question we left off after the break | | 12 | was what do you mean by the term family office? | | 13 | A They are representing my big family. It's | | 14 | a company my son, my daughter, my wife, and it's a | | 15 | company representing my family for investment. | | 16 | Q What is the name of the company? | | 17 | A Golden Spring Europe. | | 18 | Q Do you mean Golden Spring New York? | | 19 | A Roughly the name. | | 20 | Q Who pays for the meals that you eat? | | 21 | A Sometimes my wife's company, sometimes my | | 22 | family office, my son's company. | | 23 | Q Mr. Kwok, when you use the term family | | 24 | office, are you referring to the company known as | | 25 | Golden Spring New York Limited? |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 29 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 28 | | 1 | THE OFFICIAL INTERPRETER: What's the name | | 2 | of the company? Can I -- can you repeat it? | | 3 | MS. CLAIBORN: The name is Golden Spring | | 4 | New York Limited. | | 5 | THE WITNESS: Yes. | | 6 | BY MS. CLAIBORN: | | 7 | Q In your bankruptcy case, you filed a | | 8 | report covering your expenses for the month of | | 9 | February. | | 10 | THE OFFICIAL INTERPRETER: May I repeat | | 11 | again? | | 12 | MS. CLAIBORN: Maybe I'll try it again. | | 13 | THE OFFICIAL INTERPRETER: Thank you. | | 14 | BY MS. CLAIBORN: | | 15 | Q Mr. Kwok, you filed a monthly operating | | 16 | report covering the month of February 2022, and that | | 17 | report shows you spent approximately \$160,000. | | 18 | MR. BALDIGA: Objection. I object. | | 19 | BY MS. CLAIBORN: | | 20 | Q Who funded the disbursements of \$160,000? | | 21 | A Some from the Golden Spring family office | | 22 | and the company, some were paid by my wife and my | | 23 | wife's company. | | 24 | Q What is the name of your wife's company? | | 25 | A Greenwich, in Connecticut. |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 30 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 29 | | 1 | Q Are you referring to the company? | | 2 | A Yes, the company name. | | 3 | Q What expenses does your wife company, | | 4 | Greenwich, pay for? | | 5 | A Mostly food, because I live in my wife's | | 6 | house. We share the cleaning, the expenses because | | 7 | -- and also the garden maintenance expenses. | | 8 | UNIDENTIFIED SPEAKER: Okay. Can we take | | 9 | a quick time out so I can speak with my co-counsel? | | 10 | Or with my partner. | | 11 | MR. BALDIGA: No, let's just wait. | | 12 | BY MS. CLAIBORN: | | 13 | Q Where does your wife's company, Greenwich, | | 14 | get its money from? | | 15 | A I don't know. | | 16 | Q Did your wife's company, Greenwich, pay | | 17 | for any professional expenses? | | 18 | A I don't know. | | 19 | Q Is your wife the person who actually makes | | 20 | the payments? | | 21 | A Yes. | | 22 | Q Does your wife have a checking account? | | 23 | A I don't know. | | 24 | Q Does your wife have a debit card? | | 25 | A I don't know. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 31 of 134 | |---------------|-------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 30 | | 1 | Q | When you eat in a restaurant with your | | 2 | | wife, who pays the bill? | | 3 | A | I never went to a restaurant with my wife. | | 4 | Q | Ever? | | 5 | A | I think I was chased by these people and I | | 6 | never went. | Thinks I -- you know, I think I was | | 7 | | chased by these people. | | 8 | Q | Does your wife buy groceries? | | 9 | A | Sometimes. | | 10 | Q | How does she pay for them? | | 11 | A | I don't know. | | 12 | Q | Why does Golden Spring New York pay for | | 13 | | some of your personal expenses? | | 14 | A | Because I'm one of the family member, and | | 15 | | my son is very successful and he loves me very much. | | 16 | Q | Is there any other reason? | | 17 | A | I don't know. | | 18 | Q | What personal living expenses of yours | | 19 | | does Golden Spring pay for? | | 20 | A | The expense from security because I was | | 21 | | chased by the people in the back, and the | | 22 | | transportation, clothing, and some items for living. | | 23 | Q | Who is the person at Golden Spring New | | 24 | York -- | | | 25 | | MS. CLAIBORN: Wait a minute. I'm going |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 32 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 31 | | 1 | to ask a full question. | | 2 | BY MS. CLAIBORN: | | 3 | Q So who is the person at Golden Spring New | | 4 | York who authorizes the payment of your personal | | 5 | living expenses? | | 6 | A My son. | | 7 | Q Please explain how your son authorizes | | 8 | those payments. | | 9 | A I usually communicate with Golden Spring, | | 10 | the company's manager and CEO. | | 11 | THE PRIVATE INTERPRETER: (Indiscernible) | | 12 | director, not manager. | | 13 | THE OFFICIAL INTERPRETER: Could you -- | | 14 | okay. Director, not a manager. | | 15 | MR. BALDIGA: Thank you. | | 16 | BY MS. CLAIBORN: | | 17 | Q Mr. Kwok, who is the director or manager | | 18 | that you just referred to? | | 19 | A Wang Yanping. | | 20 | Q Is Ms. Ping a officer of Golden Spring New | | 21 | York? | | 22 | A She is a Miss. She's a lady. | | 23 | Q Is Ms. Ping a corporate officer of Golden | | 24 | Spring New York? | | 25 | A Yes. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 33 of 134 | |---------------|-------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 32 | | 1 | Q | What is her title? | | 2 | A | She is a officer or director. | | 3 | Q | Does she have a position title? | | 4 | A | I don't know. | | 5 | Q | Mr. Kwok, are you a corporate officer of | | 6 | | Golden Spring New York? | | 7 | A | Now? | | 8 | Q | Yes. | | 9 | A | No. | | 10 | Q | Mr. Kwok, have you ever been in the past, | | 11 | | a corporate officer of Golden Spring New York? | | 12 | A | I seem to hold a title when the company | | 13 | | was established in 2015. I forgot what title was it | | 14 | then. | | | 15 | Q | Mr. Kwok, do you own any interest in | | 16 | | Golden Spring New York? | | 17 | A | No. | | 18 | Q | In the past, have you ever had any kind of | | 19 | | ownership interest in Golden Spring New York? | | 20 | A | No. | | 21 | Q | Were you involved in the formation of | | 22 | | Golden Spring New York? | | 23 | A | Yes. | | 24 | Q | What was your role in the formation of | | 25 | | Golden Spring New York? |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 of 134 | Entered 03/27/23 14:12:10 | Page 34 | |---------------|-------------------|--------------------------------------|------------------------------------------------------|---------| | | | Ho Wan Kwok - April 6, 2022 | | 33 | | 1 | A | | Consultant and giving advice, suggestions. | | | 2 | Q | | Was your son involved in the formation of | | | 3 | | Golden Spring New York? | | | | 4 | A | He is the main person. | He -- he was the | | | 5 | main person. | | | | | 6 | Q | | When Golden Spring New York was created, | | | 7 | | | who had the ownership interest in New York -- Golden | | | 8 | | New -- Golden Spring New York? | | | | 9 | A | My son. | | | | 10 | Q | | Did Golden Spring Hong Kong have any | | | 11 | | | ownership interest in Golden Spring New York? | | | 12 | A | | I don't know the detail of the interest | | | 13 | | | and because this -- these two combined, it's | | | 14 | | considered one thing. | | | | 15 | Q | | Is Golden Spring Hong Kong a separate | | | 16 | | company from Golden Spring New York? | | | | 17 | A | I don't know. | | | | 18 | Q | | Who owns Golden Spring Hong Kong? | | | 19 | A | My son. | | | | 20 | Q | | In 2015, when Golden Spring New York was | | | 21 | | | formed, who owned Golden Spring Hong Kong? | | | 22 | A | I don't know. | | | | 23 | Q | | Are you a corporate officer of Golden | | | 24 | Spring Hong Kong? | | | | | 25 | A | I don't remember. | | |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 35 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 34 | | 1 | Q Have you ever been a cooperate officer of | | 2 | Golden Spring Hong Kong? | | 3 | A I don't remember. | | 4 | Q Do you have any ownership interest in | | 5 | Golden Spring Hong Kong? | | 6 | A No. | | 7 | Q Have you ever in the past, had an | | 8 | ownership interest in Golden Spring Hong Kong? | | 9 | A No. | | 10 | Q What type of business is Golden Spring New | | 11 | York engaged in? | | 12 | A I don't know. | | 13 | Q How does Golden Spring New York generate | | 14 | revenue? | | 15 | A I don't know. | | 16 | THE PRIVATE INTERPRETER: Ms. Holley, I | | 17 | don't know if this -- the (indiscernible) he said, | | 18 | how does Golden Spring New York generate revenue, | | 19 | not how does Golden Spring New York making money, | | 20 | right? | | 21 | MS. CLAIBORN: That was basically my | | 22 | question. | | 23 | THE PRIVATE INTERPRETER: Yeah, so the | | 24 | interpreter should not say -- interpret it in such a | | 25 | way that Golden Spring New York -- how does Golden |

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| | Ho Wan Kwok - April 6, 2022 35 | |----|----------------------------------------------------| | 1 | Spring New York make money, to the -- to the -- to | | 2 | Mr. Kwok. | | 3 | THE OFFICIAL INTERPRETER: Generate money, | | 4 | yeah. Generate revenue, generate money. | | 5 | THE PRIVATE INTERPRETER: No, but you said | | 6 | -- | | 7 | MS. CLAIBORN: I'm happy to ask it | | 8 | specifically. | | 9 | BY MS. CLAIBORN: | | 10 | Q How does Golden Spring New York make | | 11 | money? | | 12 | A I don't know. | | 13 | Q In the year 2015, were you involved in | | 14 | Golden Spring New York's business? | | 15 | A I don't remember. | | 16 | Q Have you ever given a gift of money to | | 17 | Golden Spring New York? | | 18 | A No. | | 19 | Q Have you ever given any money to Golden | | 20 | Spring New York? | | 21 | A No. | | 22 | Q Have you ever transferred any property of | | 23 | any kind to Golden Spring New York? | | 24 | A No. | | 25 | Q Have you ever funded Golden Spring New |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 37 of 134 | | |---------------|-------------------|------------------------------------------------------------------|----| | | | Ho Wan Kwok - April 6, 2022 | 36 | | 1 | York in any way? | | | | 2 | A | No. | | | 3 | Q | Have you ever loaned money to Golden | | | 4 | Spring New York? | | | | 5 | A | No. | | | 6 | Q | Have you ever invested any of your own | | | 7 | | money in Golden Spring New York? | | | 8 | A | No. | | | 9 | Q | What corporate position does Yanping Wang | | | 10 | Hold? | | | | 11 | A | Officer and director. | | | 12 | Q | Is Yanping Wang the president of Golden | | | 13 | Spring New York? | | | | 14 | A | Yes. | | | 15 | Q | Does Golden Spring New York have any other | | | 16 | | corporate officers? | | | 17 | A | Yes. | | | 18 | Q | Who are they? | | | 19 | A | I don't remember clearly about their | | | 20 | names. | | | | 21 | Q | Please tell me what you remember. | | | 22 | A | What -- I don't remember their names | | | 23 | | clearly and -- because I don't even remember | | | 24 | attorney's names. | I don't want to misleading you, | | | 25 | Holley. | | |

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| | | Ho Wan Kwok - April 6, 2022 37 | |----|------------------|---------------------------------------------------------| | 1 | Q | How many officers does Golden Spring New | | 2 | York have? | | | 3 | A | I don't remember. Oh, I don't know. | | 4 | Sorry. | I don't know. | | 5 | Q | Does Golden Spring New York have any | | 6 | directors? | | | 7 | A | Yanping Wang. | | 8 | Q | Is Ms. Wang the only director of Golden | | 9 | Spring New York? | | | 10 | A | I don't know. | | 11 | Q | Where does Golden Spring New York get the | | 12 | | money that it uses to pay your personal expenses? | | 13 | A | I don't know. | | 14 | Q | Does Golden Spring New York have any | | 15 | employees? | | | 16 | A | Yes. | | 17 | Q | How many? | | 18 | A | I don't know. | | 19 | Q | Are you currently involved in any way in | | 20 | | the business of Golden Spring New York? | | 21 | A | No. | | 22 | Q | What does Golden Spring New York own? | | 23 | A | I don't know. | | 24 | Q | Golden Spring New York is willing to loan | | 25 | | you the sum of \$8 million. Where is it getting that |

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| | Ho Wan Kwok - April 6, 2022 38 | |----|-----------------------------------------------------| | 1 | \$8 million from? | | 2 | A I don't know. | | 3 | Q Are you the person who asked Golden Spring | | 4 | New York to loan you \$8 million? | | 5 | A No. | | 6 | Q Who asked Golden Spring New York to loan | | 7 | you \$8 million? | | 8 | A My attorney. | | 9 | Q Which attorney? | | 10 | A Aaron Mitchell here. | | 11 | Q Are you referring to Aaron Mitchell? | | 12 | A Now I remember his name now. | | 13 | UNIDENTIFIED SPEAKER: Just for the | | 14 | record, I'm not sure Mr. Mitchell has registered an | | 15 | appearance yet. It would be appropriate if he's | | 16 | going to be here representing the debtor, if he | | 17 | (indiscernible) his appearance. | | 18 | MS. CLAIBORN: I believe I did read Mr. | | 19 | Mitchell's name earlier today. | | 20 | UNIDENTIFIED SPEAKER: He hasn't filed -- | | 21 | MS. CLAIBORN: He did sign -- | | 22 | UNIDENTIFIED SPEAKER: -- an appearance in | | 23 | this matter. | | 24 | MS. CLAIBORN: Thank you. Can you | | 25 | translate that? |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 of 134 | Page 40 | |---------------|-------------------|-------------------------------------------------------|---------| | | | Ho Wan Kwok - April 6, 2022 | 39 | | 1 | | THE OFFICIAL INTERPRETER: I didn't hear | | | 2 | totally clearly. | I know it's some distance. I | | | 3 | don't -- | | | | 4 | BY MS. CLAIBORN: | | | | 5 | Q | Does Golden Spring New York have any bank | | | 6 | accounts? | | | | 7 | A | I don't know. | | | 8 | Q | Do you have access to Golden Spring New | | | 9 | | York's financial accounts? | | | 10 | A | No. | | | 11 | Q | Do you have authority to enter into | | | 12 | | financial transactions on behalf of Golden Spring | | | 13 | New York? | | | | 14 | A | No. | | | 15 | | THE PRIVATE INTERPRETER: No. No, that's | | | 16 | not the question. | | | | 17 | | THE OFFICIAL INTERPRETER: What was it? | | | 18 | | MS. CLAIBORN: I'm happy to repeat the | | | 19 | question. | | | | 20 | BY MS. CLAIBORN: | | | | 21 | Q | Do you have authority to enter into | | | 22 | | financial transactions on behalf of Golden Spring | | | 23 | New York? | Mr. Kwok, if you don't answer -- if you | | | 24 | | don't understand my question -- | | | 25 | | THE OFFICIAL INTERPRETER: He's asking if | |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 41 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 40 | | 1 | he -- if I was asking if he has the right to use the | | 2 | -- the Golden Spring New York, the accounts for | | 3 | transactions. You know. | | 4 | MS. CLAIBORN: That was not my question. | | 5 | BY MS. CLAIBORN: | | 6 | Q Mr. Kwok, are you authorized to enter into | | 7 | any kind of financial transactions on behalf of | | 8 | Golden Spring New York? | | 9 | A No. | | 10 | MR. BALDIGA: Excuse me, the interpreter | | 11 | might have a comment. | | 12 | MS. CLAIBORN: Can you translate that, | | 13 | please? | | 14 | THE OFFICIAL INTERPRETER: Yeah. She said | | 15 | that it's the trading -- trading of the financial | | 16 | trading -- | | 17 | THE PRIVATE INTERPRETER: Transaction. | | 18 | THE OFFICIAL INTERPRETER: -- transaction | | 19 | to -- | | 20 | THE PRIVATE INTERPRETER: Not trading. | | 21 | THE OFFICIAL INTERPRETER: He said that, | | 22 | no, he was not -- I was not authorized to do the | | 23 | transactions, financial transactions. | | 24 | BY MS. CLAIBORN: | | 25 | Q What, if anything, do you currently do for |

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| | Ho Wan Kwok - April 6, 2022 | |----|----------------------------------------------------| | 1 | Golden Spring New York? | | 2 | A No. | | 3 | Q Is Golden Spring New York funding your | | 4 | son's personal living expenses? | | 5 | A I don't know. | | 6 | Q Is Golden Spring New York funding your | | 7 | daughter's personal living expenses? | | 8 | A I don't know. | | 9 | Q Do you owe any money to Golden Spring New | | 10 | York? | | 11 | A Yes. | | 12 | Q How much? | | 13 | A Like more than \$21 million. | | 14 | Q How do you owe more than \$21 million to | | 15 | Golden Spring New York? | | 16 | A Because in the past five years and I was | | 17 | sued by a lot of creditors. | | 18 | Q Did Golden Spring New York -- | | 19 | MS. CLAIBORN: I apologize. | | 20 | THE OFFICIAL INTERPRETER: I just ask him | | 21 | to repeat. | | 22 | THE WITNESS: In the past five years, I | | 23 | was chased by Chinese Communist Party. | | 24 | THE OFFICIAL INTERPRETER: I didn't get | | 25 | it. Ask -- I'm asking him to repeat it one more |

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| 1 | time. | |----|--------------------------------------------------------| | 2 | MR. BALDIGA: Short -- short answer. | | 3 | THE WITNESS: In the past five years I was | | 4 | trapped -- trapped by some of the cases from Chinese | | 5 | Communist Party, designed by the Chinese Communist | | 6 | Party, including the case past, that case. I need | | 7 | to -- need to pay a large amount of legal fees so | | 8 | that's why I got the support from the Golden Spring | | 9 | New York. This is the main reason I owe \$21 | | 10 | million. | | 11 | THE PRIVATE INTERPRETER: Interpreter | | 12 | missed that, the legal -- legal fee. | | 13 | THE OFFICIAL INTERPRETER: Yeah, I said | | 14 | the legal fee. I said that. Did I say legal fee? | | 15 | THE PRIVATE INTERPRETER: I didn't think | | 16 | so, but as long as you say that. | | 17 | BY MS. CLAIBORN: | | 18 | Q How much of the \$21 million is comprised | | 19 | of legal fees? | | 20 | THE OFFICIAL INTERPRETER: Can you repeat | | 21 | that one again? | | 22 | BY MS. CLAIBORN: | | 23 | Q How much of the \$21 million -- | | 24 | THE OFFICIAL INTERPRETER: Okay. | | 25 | BY MS. CLAIBORN: |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 44 of 134 | |---------------|------------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 43 | | 1 | Q | -- is comprised of legal fees? | | 2 | A | I think most of it is legal fee. | | 3 | Q | Why is Golden Spring New York paying your | | 4 | legal fees? | | | 5 | A | Because the Golden Spring New York is my | | 6 | | son and my family's company and they love me very | | 7 | much. | They hope -- they hoping me to live, not be | | 8 | | killed by the people behind me. | | 9 | Q | Do you have any written agreement with | | 10 | | Golden Spring New York? | | 11 | A | Yes. | | 12 | Q | What legal -- sorry. What written | | 13 | | agreements do you have with Golden Spring New York? | | 14 | A | It's agreement for borrowing -- borrowing | | 15 | money. | | | 16 | Q | When did you enter into that agreement to | | 17 | borrow money? | | | 18 | A | A few years ago. I know -- I don't know | | 19 | rough time. | | | 20 | | THE PRIVATE INTERPRETER: I don't recall. | | 21 | | MS. CLAIBORN: What -- | | 22 | | THE OFFICIAL INTERPRETER: What -- yeah, I | | 23 | | don't remember the time. | | 24 | BY MS. CLAIBORN: | | | 25 | Q | What are the terms of the legal agreement |

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| | Ho Wan Kwok - April 6, 2022 44 | | | |----|------------------------------------------------------|--|--| | 1 | with Golden Spring New York? Sorry. Let me | | | | 2 | rephrase that. What are the terms of the written | | | | 3 | agreement with Golden Spring New York? | | | | 4 | A I don't remember. | | | | 5 | UNIDENTIFIED SPEAKER: Sorry. Could you | | | | 6 | repeat the English, please? | | | | 7 | MS. CLAIBORN: Go ahead and say that -- | | | | 8 | repeat. | | | | 9 | THE OFFICIAL INTERPRETER: I don't | | | | 10 | remember. | | | | 11 | BY MS. CLAIBORN: | | | | 12 | Q Are you obligated under that written | | | | 13 | agreement with Golden Spring New York to pay back | | | | 14 | all of the money? | | | | 15 | A Yes. | | | | 16 | MR. BALDIGA: There's more to the | | | | 17 | question. | | | | 18 | BY MS. CLAIBORN: | | | | 19 | Q That Golden Spring paid to lawyers on your | | | | 20 | behalf. | | | | 21 | A Yes. | | | | 22 | THE PRIVATE INTERPRETER: It was only | | | | 23 | (indiscernible) of a difference in the interpreting. | | | | 24 | For example, the interpreter did not interpret under | | | | 25 | the agreement, are you obligated to make them all -- | | |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 46 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 45 | | 1 | to pay back all the money. All the money that is, | | 2 | you know -- | | 3 | MR. BALDIGA: Okay. | | 4 | THE PRIVATE INTERPRETER: -- spent on the | | 5 | lawyer. | | 6 | MR. BALDIGA: Maybe Holley can clarify | | 7 | that. | | 8 | THE PRIVATE INTERPRETER: Yeah. | | 9 | BY MS. CLAIBORN: | | 10 | Q I'm going to ask a long question. I'm | | 11 | going to break it into parts. | | 12 | Mr. Kwok, are you obligated to pay back | | 13 | Golden Spring New York for all of the money that | | 14 | Golden Spring New York paid to lawyers on your | | 15 | behalf? | | 16 | A Yes. | | 17 | Q Is that agreement with Golden Spring New | | 18 | York in writing? | | 19 | A Yes. | | 20 | Q Is that the same written agreement you | | 21 | mentioned a few minutes ago? | | 22 | A Yes. | | 23 | Q Do you have more than one written | | 24 | agreement with Golden Spring New York? | | 25 | A Yes. |

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| | Ho Wan Kwok - April 6, 2022 46 | |----|------------------------------------------------------| | 1 | Q What are your other written agreements | | 2 | with Golden Spring New York? | | 3 | A In the past week, I had a case with Logan | | 4 | Cheng. The settlement with Logan Cheng, the money | | 5 | from -- for the settlement is the money I borrow | | 6 | from Golden Spring New York. | | 7 | Q Do you have any other written agreements | | 8 | with Golden Spring New York? | | 9 | A I don't remember. | | 10 | Q Does Golden Spring New York have a fee | | 11 | agreement with any of the attorneys who represent | | 12 | you in litigation? | | 13 | Can you -- can you answer, Mr. Kwok? | | 14 | THE OFFICIAL INTERPRETER: Any agreement | | 15 | with -- can you repeat one more time? | | 16 | BY MS. CLAIBORN: | | 17 | Q Does Golden Spring New York have a -- any | | 18 | kind of a fee agreement with any of the lawyers who | | 19 | represent Mr. Kwok in litigation? | | 20 | A I don't know. | | 21 | Q Mr. Kwok, who represents you in the | | 22 | litigation you filed against UBS in London? | | 23 | A Attorney -- attorney office in London. | | 24 | Q What is the name? | | 25 | A I don't remember completely about the |

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| | Ho Wan Kwok - April 6, 2022 | | | | |----|---------------------------------------------------|--|--|--| | 1 | English name. | | | | | 2 | Q Does Golden Spring New York have a fee | | | | | 3 | agreement with that attorney in London? | | | | | 4 | A There should be. | | | | | 5 | MR. BALDIGA: I'm sorry. What was the | | | | | 6 | answer? | | | | | 7 | THE OFFICIAL INTERPRETER: Should have. | | | | | 8 | BY MS. CLAIBORN: | | | | | 9 | Q Do you know if it does have enough -- have | | | | | 10 | a fee agreement? | | | | | 11 | A I'm not sure. | | | | | 12 | Q Who is the person at Golden Spring New | | | | | 13 | York who authorized payment of your litigation | | | | | 14 | expenses? | | | | | 15 | A My son. | | | | | 16 | Q Does your son have to speak with anyone | | | | | 17 | else in order to use Golden Spring New York money | | | | | 18 | for your benefit? | | | | | 19 | A Yes. | | | | | 20 | Q Who does your son need to speak with? | | | | | 21 | A He needs to talk to my family member, | | | | | 22 | which includes more than 100 family members, and | | | | | 23 | that because they have a fund. | | | | | 24 | THE PRIVATE INTERPRETER: That -- the | | | | | 25 | number is 181. | | | |

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Ho Wan Kwok - April 6, 2022

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| 1 | BY MS. CLAIBORN: | |----|--------------------------------------------------------| | 2 | Q Mr. Kwok, if your son wanted to give you | | 3 | \$100, would he have to seek authority from someone | | 4 | at Golden Spring New York? | | 5 | A I don't know. | | 6 | Q When you say your son has to speak with | | 7 | someone at Golden Spring New York, how many people | | 8 | does he need to speak with? | | 9 | A I don't know details. | | 10 | Q With respect to the \$8 million that Golden | | 11 | Spring New York is willing to loan you, did your son | | 12 | have to obtain consent of other people at Golden | | 13 | Spring New York for that transaction? | | 14 | A I don't know. | | 15 | Q Have you ever been to the office of Golden | | 16 | Spring New York in New York City? | | 17 | A Yes. | | 18 | Q How often do you go to the Golden Spring | | 19 | New York office in New York City? | | 20 | A Not -- not fixed. Sometimes I go there a | | 21 | few times a month. Sometimes I haven't -- I haven't | | 22 | gone there for a few months. | | 23 | Q When was the last time you went to the | | 24 | Golden Spring New York office? | | 25 | A Yesterday. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 of 134 | Entered 03/27/23 14:12:10 | Page 50 | |---------------|-----------------------|-------------------------------------|--------------------------------------------|---------| | | | Ho Wan Kwok - April 6, 2022 | | 49 | | 1 | Q | Why did you go? | | | | 2 | A | | For preparing today's meeting. | | | 3 | Q | | Did your son speak with Yanping Wang about | | | 4 | the \$8 million loan? | | | | | 5 | A | I don't know. | | | | 6 | Q | | Did you negotiate the terms of the \$8 | | | 7 | | | million loan from Golden Spring New York? | | | 8 | A | No. | | | | 9 | Q | | Who was the person who negotiated the \$8 | | | 10 | | million loan on your behalf? | | | | 11 | A | My attorney. | | | | 12 | Q | Which attorney? | | | | 13 | A | Aaron Mitchell. | | | | 14 | Q | | Who did Attorney Aaron Mitchell negotiate | | | 15 | | with at Golden Spring New York? | | | | 16 | | THE OFFICIAL INTERPRETER: | Can you repeat | | | 17 | one? | | | | | 18 | BY MS. CLAIBORN: | | | | | 19 | Q | | Who did Attorney Aaron Mitchell negotiate | | | 20 | | with at Golden Spring New York? | | | | 21 | A | I don't know. | My son. | | | 22 | Q | | Did you borrow the sum of \$1 million from | | | 23 | | Lamp Capital, LLC in February 2022? | | | | 24 | A | Yes. | | | | 25 | Q | | Is that loan from Lamp Capital, LLC in | |

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| | | Ho Wan Kwok - April 6, 2022 | 50 | |----|---------------|-------------------------------------------|----| | 1 | writing? | | | | 2 | A | No. | | | 3 | Q | What are the loan terms of the loan from | | | 4 | Lamp Capital? | | | | 5 | A | I don't know detail. | | | 6 | Q | Who are the members of Lamp Capital, LLC? | | | 7 | A | My son. | | | 8 | Q | Are there any other members of Lamp | | | 9 | Capital, LLC? | | | | 10 | A | I don't know. | | | 11 | Q | Who is the managing member of Lamp | | | 12 | Capital, LLC? | | | | 13 | A | I don't know. | | | 14 | Q | Who was the person at Lamp Capital who | | | 15 | | authorized the loan? | | | 16 | A | My son. | | | 17 | Q | What are the assets of Lamp Capital, LLC? | | | 18 | A | I don't know. | | | 19 | Q | What does Lamp Capital own? | | | 20 | A | I don't know. | | | 21 | Q | Have you ever funded Lamp Capital in any | | | 22 | way? | | | | 23 | A | No. | | | 24 | Q | Have you ever invested any money in Lamp | | | 25 | Capital, LLC? | | |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 52 of 134 | |---------------|-------------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 51 | | 1 | A | No. | | 2 | Q | Why did Lamp Capital loan you the \$1 | | 3 | | million and not Golden Spring New York? | | 4 | A | I don't know. | | 5 | Q | What is the source of the \$1 million that | | 6 | | Lamp Capital loaned to you? | | 7 | A | I don't know. | | 8 | | MS. CLAIBORN: Why don't we take a five | | 9 | | minute break for the restroom? We'll reconvene | | 10 | | actually, at 12:10. | | 11 | (Recess) | | | 12 | | MS. CLAIBORN: We are back on the record | | 13 | | after a short break. | | 14 | | Mr. Kwok, you remain under oath. | | 15 | BY MS. CLAIBORN: | | | 16 | Q | Mr. Kwok, were you involved in the | | 17 | | selection of the lawyers who represent you in your | | 18 | action in London? | | | 19 | A | Yes. | | 20 | Q | Did your counsel in London request a | | 21 | retainer? | | | 22 | A | Yes. | | 23 | Q | And did you pay your counsel in London a | | 24 | retainer? | | | 25 | A | Yes. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 53 of 134 | |---------------|-----------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 52 | | 1 | Q | How much? | | 2 | A | 300,000 pound. | | 3 | Q | And when was that 300,000 pound retainer | | 4 | paid? | | | 5 | A | Roughly two years ago. | | 6 | Q | Who funded the retainer? | | 7 | A | My son helped to pay -- pay that. | | 8 | Q | Did your son pay all of the retainer? | | 9 | A | Yes. | | 10 | Q | Did your son pay the retainer out of his | | 11 | personal funds? | | | 12 | A | Should be from the company, England. | | 13 | Q | What was the name of the company who paid | | 14 | the retainer? | | | 15 | A | I don't remember. | | 16 | Q | Did Golden Spring New York pay the | | 17 | | retainer to your London counsel? | | 18 | A | I don't remember details because other | | 19 | | than the retainer and the other -- a few more | | 20 | | payments in -- you know, after. | | 21 | Q | Mr. Kwok, if you wanted to go buy a pair | | 22 | | of shoes, how would you pay for a pair of shoes? | | 23 | A | I will ask Golden Spring New York to pay | | 24 | for it. | | | 25 | Q | And how would that process work? |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 of 134 | Entered 03/27/23 14:12:10 | Page 54 | |---------------|------------------|------------------------------|----------------------------------------------------|-------------| | | | Ho Wan Kwok - April 6, 2022 | | 53 | | 1 | A | | And I will talk to the director and E Wa | | | 2 | | | Wang (ph) and ask her to contact -- talk to my son | | | 3 | | and to pay for the shoes. | | | | 4 | Q | | How does the shoe company get the money? | | | 5 | The shoe store. | | | | | 6 | A | I don't know. | Usually, it's E Wa Wang and | | | 7 | | | communicate, because my English ability is not | | | 8 | | capable to communicate. | | | | 9 | Q | | If you went to a store, tried on shoes, | | | 10 | | | and wanted to take them home from the store, how | | | 11 | | would you pay for the shoes? | | | | 12 | A | | In the recent few years I basically never | | | 13 | | bought a pair of shoes. | | | | 14 | Q | | What was the last thing you paid for? | | | 15 | A | | Recently, I didn't go to buy anything. | | | 16 | | MR. BALDIGA: | I'm sorry. Could you repeat | | | 17 | that? | | | | | 18 | | THE OFFICIAL INTERPRETER: | Recently, I | | | 19 | | didn't go to buy anything. | | | | 20 | BY MS. CLAIBORN: | | | | | 21 | Q | | My question wasn't recently. | My question | | 22 | | | was, what was the last thing that you purchased? | | | 23 | A | I don't remember. | | | | 24 | Q | | Do you ever eat in a restaurant? | | | 25 | A | Recent years, I didn't. | | |

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| | Ho Wan Kwok - April 6, 2022 54 | |----|------------------------------------------------------| | 1 | Q Before COVID 19, did you eat in | | 2 | restaurants? | | 3 | A Very rare because I was afraid to be | | 4 | killed by the people behind me, because I was always | | 5 | in the process getting chased. | | 6 | Q When you ate in a restaurant, were you the | | 7 | person who paid the bill? | | 8 | A I don't have money to pay, so that's why I | | 9 | don't go there. | | 10 | Q Mr. Kwok, if you wanted to go buy a cup of | | 11 | coffee, how would you pay for it? | | 12 | A I never bought a cup of coffee. I was -- | | 13 | I'm afraid the people behind me might poison me in | | 14 | the coffee. | | 15 | Q Mr. Kwok, if you wanted to buy water, | | 16 | you're out and about and you want to buy water, how | | 17 | would you pay for it? | | 18 | A Well, since 2107, I don't -- I didn't go | | 19 | out to buy water outside. | | 20 | THE PRIVATE INTERPRETER: There was a | | 21 | (indiscernible) difference in the nuance. | | 22 | THE OFFICIAL INTERPRETER: Can you -- can | | 23 | you repeat it -- can you repeat -- | | 24 | THE WITNESS: Since 2017, I never went | | 25 | outside, walk around, and then buy water or coffee. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 56 of 134 | |---------------|------------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 55 | | 1 | BY MS. CLAIBORN: | | | 2 | Q | Mr. Kwok, do you have any interest in any | | 3 | mutual funds? | | | 4 | A | No. | | 5 | Q | Do you own any bonds? | | 6 | A | No. | | 7 | Q | Do you own any publically traded stock in | | 8 | any company? | | | 9 | A | No. | | 10 | Q | Do you own any cars? | | 11 | A | No. | | 12 | Q | Do you have access to any cars? | | 13 | A | Yes. | | 14 | Q | And whose cars do you have access to? | | 15 | A | My son's and Golden Springs. | | 16 | Q | Does Golden Spring provide you with a car | | 17 | | that's yours to use? | | 18 | A | Yes. | | 19 | Q | What kind of car is that? | | 20 | A | Maybach | | 21 | | THE PRIVATE INTERPRETER: Maybach. | | 22 | | THE OFFICIAL INTERPRETER: Huh? | | 23 | | THE PRIVATE INTERPRETER: Maybach. | | 24 | | THE OFFICIAL INTERPRETER: Maybach? Okay. | | 25 | | I don't know the name of it. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 57 of 134 | |---------------|-------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 56 | | 1 | | THE WITNESS: Maybach. | | 2 | | BY MS. CLAIBORN: | | 3 | Q | Mr. Kwok, do you have a driver's license? | | 4 | A | I have a Hong Kong's driver's license. | | 5 | Q | Do you drive in the United States? | | 6 | A | Almost no. | | 7 | Q | When you do drive, whose car do you drive? | | 8 | A | Golden Spring's. | | 9 | Q | Do you keep a car at your Greenwich | | 10 | residence? | | | 11 | A | Yes. | | 12 | Q | And what car is that? | | 13 | A | Maybach. | | 14 | Q | Do you own any aircraft? | | 15 | A | No. | | 16 | Q | Have you ever owned any aircraft? | | 17 | A | Before, yes. | | 18 | Q | When did you own aircraft? | | 19 | A | Probably 2010 to 2016. | | 20 | Q | How many air craft did you own? | | 21 | A | One. | | 22 | Q | And what was it? | | 23 | A | Airbus 319. 319. | | 24 | Q | And what happened to the Airbus 319? | | 25 | A | It was confiscated by UBS and the Chinese |

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| | | Ho Wan Kwok - April 6, 2022 | 57 | |----|--------------------|---------------------------------------------------|----| | 1 | Communist Party. | | | | 2 | Q | Okay. Do you own any water craft? | | | 3 | A | No. | | | 4 | Q | Who owns the yacht known as the Lady May? | | | 5 | A | My daughter. | | | 6 | Q | Does your daughter own the Lady May in her | | | 7 | personal name? | | | | 8 | A | Should be from a company. | | | 9 | Q | And what is the name of the company that | | | 10 | owns the Lady May? | | | | 11 | A | I don't know. | | | 12 | Q | Where is the Lady May currently? | | | 13 | A | I don't know. | | | 14 | Q | Since the bankruptcy filing, have you | | | 15 | | asked your daughter to return the Lady May to New | | | 16 | York? | | | | 17 | A | I did ask her and asked her to talk to her | | | 18 | | attorney to return the boat back to New York. | | | 19 | Q | When did you have that conversation? | | | 20 | A | Last month, after the court date. After | | | 21 | met with you. | | | | 22 | Q | And what did your daughter say? | | | 23 | A | She said that she would talk to her | | | 24 | | attorney and then talk to my attorney. | | | 25 | Q | Did your daughter agree to have the Lady | |

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| | Ho Wan Kwok - April 6, 2022 58 | |----|------------------------------------------------------| | 1 | May return to New York? | | 2 | A She was not willing to talk to me in any | | 3 | detail. She want -- she wanted to talk to her | | 4 | attorney. | | 5 | Q Did your daughter say no to your request | | 6 | that she return the Lady May to New York? | | 7 | A No, he didn't -- she didn't. | | 8 | THE PRIVATE INTERPRETER: The question was | | 9 | not completely interpreted. | | 10 | THE OFFICIAL INTERPRETER: I know, but she | | 11 | -- she already -- he already answered and -- | | 12 | MR. BALDIGA: Wait until he finishes. | | 13 | THE WITNESS: No, he -- no. | | 14 | BY MS. CLAIBORN: | | 15 | Q Mr. Kwok, do you own or have an interest | | 16 | in any trust? | | 17 | A No. | | 18 | Q Are you the beneficiary of any trusts? | | 19 | A No. | | 20 | Q This is a long question. Mr. Kwok, where | | 21 | is the \$12,000 check paid to you in connection with | | 22 | your lawsuit against Baosheng Guo? | | 23 | A It's in attorney's escrow account. | | 24 | Q What is the name of the attorney who is | | 25 | holding the check? |

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| | Ho Wan Kwok - April 6, 2022 59 | |----|---------------------------------------------------| | 1 | A I can't pronounce the attorney's name | | 2 | completely. | | 3 | Q What is the attorney's first name? | | 4 | A I cannot -- I'm not able to read out the - | | 5 | - the pronounce his name. | | 6 | Q Is the attorney who's holding the check | | 7 | the same attorney who represented you in that | | 8 | lawsuit? | | 9 | A It should be. | | 10 | Q On your Schedule A-B, you did not disclose | | 11 | that \$12,000 check. Why? | | 12 | MR. BALDIGA: Wait for a question. No. | | 13 | Could he interpret that? | | 14 | BY MS. CLAIBORN: | | 15 | Q Why did you not disclose that \$12,000 | | 16 | check? | | 17 | A My attorney thinks because the money is | | 18 | not in my account, so I'm not allowed to -- we're | | 19 | not -- I'm not supposed to disclose that. | | 20 | Q Okay. Mr. Kwok, do you have any patents? | | 21 | A No. | | 22 | Q Do you have any copyrights? | | 23 | A No. | | 24 | Q Do you have any intellectual property of | | 25 | any kind? |

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| 1 | A No. | |----|-----------------------------------------------------| | 2 | MR. BALDIGA: Excuse me. Holley, I'm not | | 3 | sure if you're going to come back to it, but there | | 4 | is a reference to the \$12,000. | | 5 | MS. CLAIBORN: I did see that. | | 6 | MR. BALDIGA: Oh, you said he didn't | | 7 | disclose it. | | 8 | MS. CLAIBORN: He did not. It's not in | | 9 | response to the questions on Schedule A-B. | | 10 | MR. BALDIGA: It's right there. | | 11 | MS. CLAIBORN: We can disagree about | | 12 | whether or not it's disclosed, but it's my position | | 13 | that it's not disclosed. I understand you might | | 14 | take a different position. | | 15 | BY MS. CLAIBORN: | | 16 | Q Mr. Kwok, do you own any interest in a | | 17 | company called Ace Decade Holdings Limited? | | 18 | A Yes. | | 19 | Q What is the nature of your ownership | | 20 | interest in Ace Decade Holdings Limited? | | 21 | A So I have the interest and ask for UBS to | | 22 | pay back \$500 million. That kind of interest. | | 23 | Q Are you the only legal owner of Ace Decade | | 24 | Holdings Limited? | | 25 | THE OFFICIAL INTERPRETER: Are you the |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 62 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 61 | | 1 | only -- can you repeat that question? | | 2 | BY MS. CLAIBORN: | | 3 | Q Are you the only legal owner of Ace | | 4 | Decades? | | 5 | A I am a legal representing owner. | | 6 | Q Are there any other owners of Ace Decade? | | 7 | A No. | | 8 | Q When did you become an owner of Ace Decade | | 9 | Holdings Limited? | | 10 | A At the end of 2014. | | 11 | Q This is a long question. In your | | 12 | litigation in London against UBS, you are an | | 13 | individual plaintiff. What is the basis for your | | 14 | claim as an individual plaintiff? | | 15 | A Because I'm the 100 percent representative | | 16 | for Ace Decade. | | 17 | Q In the litigation against UBS in London, | | 18 | there is an allegation that Ace Decade gave \$500 | | 19 | million to Dawn State Limited. Where did Ace Decade | | 20 | get the \$500 million? | | 21 | A I loan from my family. | | 22 | Q Did you borrow money from your family and | | 23 | give it to Ace Decade? | | 24 | A Yes. | | 25 | MS. CLAIBORN: I don't think that was -- |

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| | Ho Wan Kwok - April 6, 2022 62 | |----|-------------------------------------------------------| | 1 | let's start over, because I don't think that was -- | | 2 | that was -- | | 3 | THE PRIVATE INTERPRETER: Yeah, I thought | | 4 | that it was -- | | 5 | MS. CLAIBORN: -- that was the question, | | 6 | because it didn't involve Dawn State -- | | 7 | THE PRIVATE INTERPRETER: Yes. | | 8 | MS. CLAIBORN: -- so I'm going to start | | 9 | over. | | 10 | BY MS. CLAIBORN: | | 11 | Q Where did you get the money to give to Ace | | 12 | Decade, the 500 million? | | 13 | MR. BALDIGA: I don't think he said he did | | 14 | that. I think he said his family did that, but you | | 15 | can ask that, but I -- | | 16 | THE WITNESS: From my family. | | 17 | BY MS. CLAIBORN: | | 18 | Q Who specifically in your family gave you | | 19 | money that you then gave to Ace Decade? | | 20 | A John Way (ph). | | 21 | Q Who is John Way? | | 22 | A A member from my family. | | 23 | Q Is he a relative of yours? | | 24 | A It's my older brother's cousin or -- | | 25 | THE PRIVATE INTERPRETER: Son-in-law. |

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| | Ho Wan Kwok - April 6, 2022 | |----|----------------------------------------------------------| | 1 | THE OFFICIAL INTERPRETER: Son-in-law? | | 2 | Okay. Sorry. | | 3 | BY MS. CLAIBORN: | | 4 | Q On your Schedule A-B, you list a possible | | 5 | malpractice claim against Boise Schiller. Can you | | 6 | please explain what that is? | | 7 | A He was the one -- he was the one | | 8 | represented me in New York to have a lawsuit against | | 9 | UBS. He gave a lot of forced documents to the Court | | 10 | and without my permission. He also threatened my | | 11 | family. He also threaten myself after drinking. He | | 12 | brought a lot of loss to us, including providing any | | 13 | English/Chinese translated documents to me before | | 14 | present them to the -- to the lawyer, or to the | | 15 | judge. That's why I -- that's why we sue him. | | 16 | Q Have you hired an attorney to represent | | 17 | you in that malpractice action? | | 18 | A My son is in the process of dealing with | | 19 | that. | | 20 | Q Why is your son talking to lawyers about | | 21 | your malpractice claim? | | 22 | A Because I need to borrow money from him. | | 23 | Q Has a lawyer been selected? | | 24 | A Not yet. | | 25 | Q Mr. Kwok, do you own an interest in any |

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| | Ho Wan Kwok - April 6, 2022 64 | |----|-------------------------------------------------------| | 1 | company aside from Ace Decade? | | 2 | A No, but the -- I own the Bravo Luck, the | | 3 | apartment, only for a few months, some of the | | 4 | interest. And because the apartment is a co-op, so | | 5 | they used my name to buy the apartment after I -- | | 6 | after we bought apartment, and then we returned the | | 7 | stock interest back. | | 8 | UNIDENTIFIED SPEAKER: I'm sorry. He must | | 9 | have spoken for 30, 40 seconds. Clearly said more | | 10 | than that. Is there a more fulsome translation? | | 11 | THE OFFICIAL INTERPRETER: Did I miss | | 12 | anything? | | 13 | MS. CLAIBORN: Let me see if I can follow | | 14 | up. | | 15 | BY MS. CLAIBORN: | | 16 | Q Mr. Kwok, do you own, currently, an | | 17 | interest in Bravo Luck? | | 18 | A No. | | 19 | Q Mr. Kwok, do you own an interest in any | | 20 | limited liability company? | | 21 | A No. | | 22 | Q Mr. Kwok, do you own an interest in any | | 23 | partnership? | | 24 | A I used to own the plane company called the | | 25 | Orange or Shiny Time, but that was before and |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 66 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 65 | | 1 | doesn't exist anymore. | | 2 | Q Mr. Kwok, do you currently own an interest | | 3 | in any partnership? | | 4 | A No. | | 5 | Q Mr. Kwok, do you currently own an interest | | 6 | in any joint venture? | | 7 | A No. | | 8 | Q Other than Ace Decade, do you own an | | 9 | interest in any other company right now? | | 10 | A No. I only owned the Orange and Shiny | | 11 | Time before, but not right now. | | 12 | Q Does Golden Spring New York have a | | 13 | security interest in any of your litigation? | | 14 | A I owe them money. | | 15 | Q Have you granted to Golden Spring New | | 16 | York, any interest in any of your assets, anything | | 17 | that you own? | | 18 | A No. | | 19 | Q So if you were to win a lawsuit against | | 20 | Golden Spring -- sorry. Wrong name. So if you were | | 21 | to win a lawsuit against UBS, would any of the money | | 22 | that you win have to be paid to Golden Spring? | | 23 | A Yes. | | 24 | Q And how much would that be? | | 25 | A Before it was 2,200 1 million, or -- |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 67 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 66 | | 1 | THE PRIVATE INTERPRETER: 21 million. | | 2 | THE WITNESS: 21 million. 21 million and | | 3 | plus now. Probably it's about 300 million. 30 | | 4 | million. Or 30 million. Yeah. | | 5 | BY MS. CLAIBORN: | | 6 | Q Is there a document that says that any | | 7 | litigation winnings you receive need to be paid to | | 8 | Golden Spring? | | 9 | A Yes. | | 10 | Q What is the name of that document? | | 11 | THE OFFICIAL INTERPRETER: I'm going to | | 12 | ask him to repeat it. | | 13 | I didn't get it. I just ask him to break | | 14 | it down, then I didn't hear what -- | | 15 | THE WITNESS: I have a case in DC. There | | 16 | is a attorney office representing me for political | | 17 | asylum and it was attacked by the cyber attack from | | 18 | the Chinese Communists, and so they -- the attorney | | 19 | office was closed, and they gave my personal | | 20 | information to the communist party, and then I sue | | 21 | them. And that litigation fee, attorney fee, came | | 22 | from Golden Spring New York. | | 23 | I ask for the settlement for 50,000 -- \$50 | | 24 | million. If I won that money, I will give the money | | 25 | back to Golden Springs for the money they supported |

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| | Ho Wan Kwok - April 6, 2022 67 | |----|-----------------------------------------------------------| | 1 | me for attorney fees. | | 2 | THE PRIVATE INTERPRETER: Mr. Kwok did not | | 3 | say settlement. Mr. Kwok just say, for a claim, not | | 4 | a settlement. | | 5 | THE OFFICIAL INTERPRETER: You're asking | | 6 | for \$50 million. Yeah. He ask for \$50 million for | | 7 | that lawsuit, and if he win -- if he wins the money, | | 8 | then he will return the money back to the Golden | | 9 | Spring New York. | | 10 | BY MS. CLAIBORN: | | 11 | Q My question was, what was the name of the | | 12 | document under which you would be repaying Golden | | 13 | Spring for your litigation? | | 14 | A The document is the document I -- | | 15 | THE OFFICIAL INTERPRETER: Can you repeat | | 16 | that one? | | 17 | THE WITNESS: The agreement is -- it's the | | 18 | agreement, I borrowed the money from Golden Spring | | 19 | New York to sue the attorney office. | | 20 | BY MS. CLAIBORN: | | 21 | Q And what is the name of the agreement? | | 22 | A I don't remember. | | 23 | Q Is it a promissory note? | | 24 | A I don't remember. | | 25 | Q Is it a contract? |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 69 of 134 | |---------------|-------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 68 | | 1 | A | I don't remember clearly. | | 2 | Q | Who prepared the document? | | 3 | A | Attorney. | | 4 | Q | What was the name of the attorney who | | 5 | | prepared the document? | | 6 | A | Melissa. | | 7 | Q | What is Melissa's last name? | | 8 | A | I don't know. | | 9 | Q | Did Melissa the attorney represent you in | | 10 | | drafting that document? | | 11 | A | Yes. | | 12 | Q | And who represented Golden Spring in | | 13 | | drafting that document? | | 14 | A | I don't know. | | 15 | Q | Did Golden Spring have any attorney? | | 16 | A | Yes. | | 17 | Q | You just don't remember who it was? | | 18 | A | They have a lot of attorneys. | | 19 | Q | Is there more than one written agreement | | 20 | | under which you owe money to Golden Spring New York? | | 21 | A | Yes. | | 22 | Q | How many agreements are there? | | 23 | A | Kind of two or three, or three or four. I | | 24 | | don't remember clearly. | | 25 | Q | And does someone keep track of the money |

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| | Ho Wan Kwok - April 6, 2022 69 | |----|-----------------------------------------------------| | 1 | that you borrow from Golden Spring New York? | | 2 | A My attorney will write it down. We record | | 3 | it. | | 4 | Q What's the name of that attorney? | | 5 | A Aaron Mitchell. | | 6 | Q Did you say Aaron Mitchell? | | 7 | A Oh, yes. | | 8 | Q And how does Aaron Mitchell keep track of | | 9 | the monies that you borrow from Golden Spring New | | 10 | York? | | 11 | A In detail, I don't know. | | 12 | Q Does anyone who is employed by Golden | | 13 | Spring New York keep track of the money that you | | 14 | borrow from Golden Spring New York? | | 15 | A I don't know. | | 16 | Q Have you ever seen a document from | | 17 | Attorney Aaron Mitchell showing how much you owe to | | 18 | Golden Spring New York? | | 19 | A This is the thing I -- it's something | | 20 | between me and my attorney I shouldn't answer. | | 21 | MR. BALDIGA: Can I -- I mean -- | | 22 | MS. CLAIBORN: I don't think the question | | 23 | involves -- | | 24 | MR. BALDIGA: You can -- | | 25 | MS. CLAIBORN: -- a privileged answer. |

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| | Ho Wan Kwok - April 6, 2022 70 | |----|------------------------------------------------------| | 1 | MR. BALDIGA: That's -- give me a second. | | 2 | You could answer that last question yes or no, so if | | 3 | you ask again, I think he will say yes or no, and | | 4 | then we can take it step by step. | | 5 | BY MS. CLAIBORN: | | 6 | Q Have you ever seen a document prepared by | | 7 | Attorney Mitchell that shows you how much money you | | 8 | have borrowed from Golden Spring? | | 9 | MR. BALDIGA: Wait. Wait, my instruction | | 10 | needs to be interpreted. | | 11 | THE OFFICIAL INTERPRETER: What? | | 12 | MS. CLAIBORN: Can you -- | | 13 | MR. BALDIGA: You need to instruct -- | | 14 | MS. CLAIBORN: Just please state it and | | 15 | he'll reinterpret. | | 16 | MR. BALDIGA: Please, tell the witness | | 17 | what -- I am telling the witness he may answer yes | | 18 | or no only. | | 19 | THE WITNESS: Yes. | | 20 | MS. CLAIBORN: I have other questions, but | | 21 | given the hour of the day, I thought that we could | | 22 | take a short break and then reconvene with creditors | | 23 | being given the opportunity to ask questions. | | 24 | I suggest we reconvene at 1:15. | | 25 | MR. BALDIGA: Is that okay? |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 72 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 71 | | 1 | MS. CLAIBORN: Okay. Thank you. We'll | | 2 | reconvene at 1:15. | | 3 | (Recess.) | | 4 | MS. CLAIBORN: The recording has been | | 5 | reconvened. We are back in session after a short | | 6 | break and Mr. Kwok, you remain under oath. | | 7 | And that this point, Mr. Wolman has some | | 8 | questions for you, Mr. Kwok. | | 9 | EXAMINATION BY MR. WOLMAN: | | 10 | Q Good afternoon, Mr. Kwok. | | 11 | On March 21st I was asking you some | | 12 | questions about a prior deposition, specifically | | 13 | about the times you had invoked your rights under | | 14 | the Fifth Amendment of the U.S. Constitution. | | 15 | On April 1st, 2021, were you being | | 16 | investigated for any crime? | | 17 | THE OFFICIAL INTERPRETER: April 21st? | | 18 | MR. WOLMAN: April 1st, 2021. | | 19 | THE OFFICIAL INTERPRETER: Can you repeat | | 20 | that question, sir? | | 21 | Q Were you being investigated for any crime? | | 22 | A From SET -- American SET and the | | 23 | investigating GTV and they can communicate with our | | 24 | attorney. |

Q Are you referring to the Securities and

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Ho Wan Kwok - April 6, 2022 Exchange Commission? A Yes. Q And what exactly were they investigating? MR. BALDIGA: Objection. I need to ask whether this would reveal privileged information. Would your answer to the last question be information from your attorneys? THE PRIVATE INTERPRETER: Can I just -- THE OFFICIAL INTERPRETER: She wants to help. THE PRIVATE INTERPRETER: Because he's not -- MS. CLAIBORN: I think you should just try again. Mr. Baldiga, maybe you can just repeat yourself and Mr. Jack, you can try again. THE OFFICIAL INTERPRETER: Can you repeat what you want to say? MR. BALDIGA: Mr. Wolman asked you what you were being investigated for. Is the information that you know, was that provided to you by your attorneys? THE WITNESS: Yes. MR. BALDIGA: And to answer the question would you have to divulge what you were told by your

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Ho Wan Kwok - April 6, 2022 attorneys? THE OFFICIAL INTERPRETER: Have to be what? Divulged? MR. BALDIGA: Would you have to say what you were told by your attorneys? THE WITNESS: Yes. MR. BALDIGA: Then I instruct the witness not to answer on the basis of the attorney/client privilege. MR. WOLMAN: That is not attorney/client information. MR. BALDIGA: Hold on. Let it be interpreted. MR. WOLMAN: Information learned from an attorney that is not specifically a communication for the purpose of giving advice or receiving information is not privileged information. If your attorneys says the sky is blue, that is not a privileged communication. MR. BALDIGA: His is arguing with me. There is not question to you. MR. WOLMAN: Mr. Baldiga, will you continue to instruct your client to improperly invoke the attorney/client privilege? MR. BALDIGA: I'll instruct on a question

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Ho Wan Kwok - April 6, 2022 by question basis. MR. WOLMAN: And this question, will you maintain the instruction? Mr. Kwok, are you refusing to answer my question? THE WITNESS: Yes. MR. WOLMAN: And on what basis are you refusing to answer my question? MR. BALDIGA: On the basis of instruction from counsel on account of attorney/client privilege. THE WITNESS: Because I can't answer the question because of the privilege between the attorney and me. BY MR. WOLMAN: Q Have you been formally charged by the Securities and Exchange Commission? A No. Q Has the Securities and Exchange Commission closed its investigation of you? MR. BALDIGA: I have to ask again, you can answer that yes or no, if you know. A No. Q Has the Securities and Exchange Commission brought any charges against GTV?

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 76 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 75 | | 1 | A I don't know. | | 2 | Q Have you been in the past five years | | 3 | subject to an audit by the U.S. Internal Revenue | | 4 | Service? | | 5 | A No. | | 6 | Q In the last five years have you been | | 7 | subject to an audit by the New York State taxing | | 8 | authority? | | 9 | A No. | | 10 | Q When did you become a resident of | | 11 | Connecticut? On what date? | | 12 | A The beginning of March, 2020, roughly. | | 13 | Q To be clear, you say you were a resident | | 14 | of Connecticut in March of 2020? | | 15 | A Yes. | | 16 | Q So how come in Mr. Cheng, my client's, | | 17 | lawsuit against you you signed a statement under | | 18 | oath indicating that you were a resident of the | | 19 | Sherry Netherlands Hotel? | | 20 | THE OFFICIAL INTERPRETER: Can you repeat | | 21 | that, counsel? | | 22 | Q If you were a resident of Connecticut in | | 23 | March of 2020, you signed a statement under oath in | | 24 | Mr. Cheng's lawsuit against you that you resided at | | 25 | the Sherry Netherlands Hotel. |

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| | Ho Wan Kwok - April 6, 2022 76 | |----|--------------------------------------------------| | 1 | A I don't 100 percent live in Connecticut, | | 2 | but sometimes I live in New York also. | | 3 | Q When did you start living in Connecticut | | 4 | more than 50 percent of the time? | | 5 | A Since March, 2020. | | 6 | Q You had some assets you claim seized by | | 7 | China, correct? | | 8 | A It's not mine. It's from my family. It's | | 9 | my family's. | | 10 | Q Have you ever had assets seized by China? | | 11 | A You're talking about under my name? | | 12 | Q Yes. | | 13 | A No. | | 14 | Q All right. In 2010, what was your | | 15 | personal net worth? | | 16 | A No. | | 17 | Q That wasn't a yes or no question. | | 18 | THE OFFICIAL INTERPRETER: Can I repeat | | 19 | your question again? | | 20 | MR. WOLMAN: Yes. | | 21 | Q In 2010 what was your personal net worth? | | 22 | A I didn't have any property. | | 23 | Q Have you ever had property in your name | | 24 | over \$1 million and by that I include where you | | 25 | owned an interest in a company that interest, |

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Ho Wan Kwok - April 6, 2022 therefore, contributes to your work? A Before 2000, yes. Q Okay. What was your net worth in 1999? A I never calculate in detail. Q What would you estimate it as? A Roughly around 100 million. Q And what happened to that \$100 million worth of assets? A Because in 2000 I got a Hong Kong passport and in China and they don't allow me to have any property, asset. Q Have you abandoned all claims to whatever assets you had in 1999? A Yes. Q Why have you abandoned your claims? THE OFFICIAL INTERPRETER: Abandoned what? Q Your claim to those assets? A Because I was not allowed to have any assets in China. Q If China changed its policy, would you have any right or ability to get those assets back? MR. BALDIGA: Objection. If you know, you can answer. A I don't know. Q What was your largest asset in 1999?

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| | Ho Wan Kwok - April 6, 2022 78 | |----|------------------------------------------------------| | 1 | A There was the assets from a hotel, equity | | 2 | interest of a hotel in China. | | 3 | Q And who holds that interest now? | | 4 | A Chinese Community Party. | | 5 | Q Is it held in the name of the Party? | | 6 | A China only has one autocrat government, | | 7 | the party, and our family's assets were taken -- | | 8 | were seized by them. | | 9 | Q How did your son become wealthy enough to | | 10 | fund Golden Spring and Lamp Capital? | | 11 | A Because he started very early to do | | 12 | investment and also bring brand names to China. | | 13 | Q Where did he get the money for his | | 14 | investment? | | 15 | A I don't know. | | 16 | Q Ms. Claiborn asked you about agreements | | 17 | with Golden Spring and you could not identify who | | 18 | the lawyer was for Golden Spring. Do you remember | | 19 | that? | | 20 | A True. | | 21 | Q I'd like to try to refresh -- to ask you | | 22 | potentially to refresh your memory was it a lawyer | | 23 | named Daniel? | | 24 | THE OFFICIAL INTERPRETER: He's asking | | 25 | Daniel? |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 80 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 79 | | 1 | Q Yes, Daniel Pedolsky. | | 2 | A Yes, probably and he used to be Golden | | 3 | Spring attorney and my personal attorney. | | 4 | Q Did you execute a waiver of conflict of | | 5 | interest with Mr. Pedolsky? | | 6 | THE OFFICIAL INTERPRETER: Can you repeat | | 7 | that? | | 8 | Q Did you execute a waiver of conflict of | | 9 | interest with Attorney Daniel Pedolsky? | | 10 | A I don't remember. | | 11 | Q You mentioned two or three -- or three or | | 12 | four agreements with Golden Spring. Can you identify | | 13 | each of those agreements? | | 14 | A I'm not sure. | | 15 | Q Can you describe the purpose of each of | | 16 | those agreements? | | 17 | A That loan from Golden Spring is to have a | | 18 | settlement with Logan Cheng. | | 19 | Q And did you take out a loan to pay the | | 20 | lawyers to sue Logan Cheng? | | 21 | A I don't remember. | | 22 | Q And what were the other agreements, other | | 23 | than with Mr. Cheng? | | 24 | A From D.C. -- the attorney's office from | | 25 | D.C. collect (indiscernible) I don't remember the |

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Ho Wan Kwok - April 6, 2022 name. MR. WOLMAN: All right. Thank you and this time I have to go but thank you. I'll try to dial in. MS. CLAIBORN: Thank you. Can I ask whoever is on the line if they could mute themselves, because they can hear you typing. All right. Who else would like to ask questions? Mr. Harbach. Go ahead, Mr. Harbach. MR. HARBACH: Thank you. For the record, I'm David Harbach with O'Melveny and Meyers and I represent PAACS. EXAMINATION BY MR. HARBACH: Q Mr. Kwok, I'd like to ask some clarifying questions based on questions that Ms. Claiborn asked you today. Earlier today she asked you if you owned any foreign currency and you said no. She also asked you if you owned any digital currency and you said no. My question is have you ever ordered or directed the purchase of either foreign currency or digital currency on behalf of any entity?

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| | Ho Wan Kwok - April 6, 2022 81 | |----|------------------------------------------------------| | 1 | THE OFFICIAL INTERPRETER: Can you repeat | | 2 | that? | | 3 | MR. HARBACH: Sure. | | 4 | Q My question is whether you have ordered or | | 5 | directed the purchase of any foreign currency or any | | 6 | digital currency on behalf of any entity? | | 7 | A What you mean direct? | | 8 | Q Have you directed anyone to purchase | | 9 | foreign currency or digital currency? | | 10 | A No. | | 11 | Q Ms. Claiborn asked you a couple of | | 12 | questions about access to credit cards and debit | | 13 | cards. And I want to make sure that we have your | | 14 | answer clear, because she asked you not whether you | | 15 | had any credit cards but whether you had any access | | 16 | to credit cards. I want to make sure that you | | 17 | understand the difference. | | 18 | THE OFFICIAL INTERPRETER: He's just asking | | 19 | why you want to represent Ms. Holley's asked | | 20 | questions. | | 21 | MR. HARBACH: I'm just trying to remind | | 22 | you of a question she asked you earlier today, sir. | | 23 | THE PRIVATE INTERPRETER: I don't | | 24 | understand the question. | | 25 | MR. BALDIGA: Mr. Baldiga's right. |

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| | Ho Wan Kwok - April 6, 2022 82 | |----|-------------------------------------------------------| | 1 | There's not a question pending. | | 2 | Q The question is do you understand the | | 3 | difference between having a credit card and having | | 4 | access to a credit card? | | 5 | A I believe I don't have. | | 6 | Q You don't understand the difference? | | 7 | A I don't know much. | | 8 | Q Okay. Well, let me give you an example. | | 9 | Let's talk about the Maybach. | | 10 | I believe that you represented to us today | | 11 | that you have access to the Maybach for | | 12 | transportation. Is that correct? | | 13 | A Yes. | | 14 | Q But I believe it's also your position that | | 15 | you do not own the Maybach. Isn't that right? | | 16 | A Yes. | | 17 | Q In other words, your position is the | | 18 | Maybach is not yours, right? | | 19 | A Yes. | | 20 | Q Okay. So I use that example to illustrate | | 21 | the example between owning something and having | | 22 | access to something. Does that help you? Do you | | 23 | understand the difference? | | 24 | A Now I understand you. | | 25 | Q Okay. Thank you. So returning to the |

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question about credit cards and debit cards. Do you have access to any credit cards or debit cards, whether or not they are yours? A I don't understand the difference what he means, access like if I use it myself or if I have somebody else use it. Q Well, let's take those one at a time. Let's begin with using it yourself. Has any member of your family ever provided you a credit card or a credit card number to use for yourself? A I never used. Q The other example you mentioned was perhaps a member of your family using a credit card on your behalf. Is that something that has happened? A What do you mean represent me to use? Q I'm asking about whether to your knowledge any member of your family has ever used a credit card or a debit card to purchase things for you? A My son, my daughter, my wife. They all have credit card to buy things for me. THE PRIVATE INTERPRETER: The witness did not say that, use the credit card to buy things for me. The witness said that my son, my wife bought things for me.

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| | | Ho Wan Kwok - April 6, 2022 84 | |----|------------------|-------------------------------------------------------| | 1 | | THE OFFICIAL INTERPRETER: Yeah, they used | | 2 | | their card and they both -- they all have it. They | | 3 | | all have the cards. That's what he said. | | 4 | | (Repeats interpretation) | | 5 | | THE OFFICIAL INTERPRETER: Yes, I did it | | 6 | right. | | | 7 | | THE WITNESS: And so my wife and my son | | 8 | | and my daughter have their own cards and also other | | 9 | | family members use their cards to buy things for me. | | 10 | Q | Is that ever at your direction? | | 11 | A | No. | | 12 | Q | Never. | | 13 | A | No. | | 14 | Q | Is it at your request? | | 15 | A | No. | | 16 | Q | Is Yan Ping Wang, the same as Yvette Wang? | | 17 | A | Yes. | | 18 | Q | Earlier Ms. Claiborn asked you about | | 19 | | Golden Spring Hong Kong. | | 20 | | You told her that your son owns it. Do | | 21 | you recall that? | | | 22 | A | Yes. | | 23 | Q | My question for you is since when has your | | 24 | | son owned Golden Spring Hong Kong? | | 25 | A | I don't know. |

Ho Wan Kwok - April 6, 2022 Q Has anyone else besides your son ever owned an interest in Golden Spring Hong Kong? A I don't remember. Q You also said that you didn't remember whether you were ever a corporate officer of Golden Spring Hong Kong? THE OFFICIAL INTERPRETER: Can you repeat that one? Q You also said that you did not remember whether you were ever a corpora officer of Golden Spring Hong Kong? Does that mean that it is possible that you were and you're just not certain? A I don't remember. Q Ms. Claiborn asked you in a few different ways about whether you know how Golden Spring New York is funded or makes money. Since when has Golden Spring been paying your personal living expenses? A 2015. Q So six or seven years approximately? A Since 2015 and that there was a person called Bruno Wu from Mainland China and called my family, my son, daughter and wife and so since then I start spending money coming from Golden Spring New York. Case 22-50073 Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 86 of 134

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 87 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 86 | | 1 | THE PRIVATE INTERPRETER: I don't think | | 2 | the witness says some. | | 3 | THE OFFICIAL INTERPRETER: What? | | 4 | THE PRIVATE INTERPRETER: I don't think | | 5 | the witness said some. | | 6 | THE WITNESS: Not including the son that | | 7 | they caught, my wife and daughter and a lot of my | | 8 | family members, but not my son. | | 9 | Q So approximately six or seven years that | | 10 | Golden Spring has been paying your personal | | 11 | expenses. Is that right? | | 12 | A Yes. | | 13 | Q During those six or seven years did you | | 14 | never discuss with any of your family members where | | 15 | the money was coming from? | | 16 | A Because a lot of my family members were | | 17 | caught by -- were arrested by your client, Bruno Wu, | | 18 | and so I have no communication. I cannot communicate | | 19 | with him. | | 20 | THE PRIVATE INTERPRETER: Not exactly. The | | 21 | partner of PAACS -- the partner who the counsel was | | 22 | represented, PAACS -- partner of PAACS -- | | 23 | THE OFFICIAL INTERPRETER: I don't know. | | 24 | He didn't mention anything about PAACS. | | 25 | THE WITNESS: So it's the other attorney |

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| 1 | representing the client, Bruno Wu, arrested a lot of | |----|-------------------------------------------------------| | 2 | your family members. Your client's past partner, | | 3 | one of the partners, (indiscernible) Bruno Wu and | | 4 | arrested a lot of your family members so you can't | | 5 | communicate with them. | | 6 | Q At any time since 2015 have you been in | | 7 | communication with your daughter, or your wife, or | | 8 | your son? | | 9 | A Yes. | | 10 | Q At any time that you've been in | | 11 | communication with any of those three individuals | | 12 | did you ever ask them about where Golden Spring's | | 13 | money was coming from? | | 14 | A Yes, I asked. | | 15 | Q And who did you ask? | | 16 | A I asked all three of them. | | 17 | Q And what did they say? | | 18 | A They told me because I was in the position | | 19 | of being chased so don't ask our own financial | | 20 | information. Don't ask me for anything and we will | | 21 | help you to -- we will help you as much as we can. | | 22 | Q When was that? | | 23 | A After 2017. | | 24 | Q How long after 2017? | | 25 | A I don't remember. |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 89 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 88 | | 1 | Q And when you had this conversation with | | 2 | your family were the three of them together or where | | 3 | these separate conversations? | | 4 | A Separate. | | 5 | Q And each of the three of them said more or | | 6 | less the same thing? | | 7 | A Similar. | | 8 | Q So I want to make sure I have this | | 9 | correct. You asked each of them where Golden | | 10 | Springs money was coming from and each of them said | | 11 | to you don't ask me about that because -- finish the | | 12 | sentence for me. | | 13 | A So you are making a story I don't | | 14 | understand. | | 15 | Q I'm trying to ask you to help me | | 16 | understand. I'm trying to understand the reason why | | 17 | your family members told you not to ask why your | | 18 | family members told you not to ask about where | | 19 | Golden Spring got the money. | | 20 | MR. BALDIGA: Let him ask you a question. | | 21 | Q Please tell me why each of your family | | 22 | members told you not to ask them about where Golden | | 23 | Spring money came from? | | 24 | MR. BALDIGA: Objection. If you know. | | 25 | THE OFFICIAL INTERPRETER: You're asking |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 90 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 89 | | 1 | to object the question? | | 2 | MR. BALDIGA: I objected. | | 3 | THE OFFICIAL INTERPRETER: Oh, you | | 4 | objected. | | 5 | MR. BALDIGA: I permit him to answer if he | | 6 | knows. | | 7 | THE OFFICIAL INTERPRETER: Okay. | | 8 | THE WITNESS: My daughter and wife were | | 9 | arrested by his partner and got released 2017 and | | 10 | released to New York. They were tortured | | 11 | tremendously by communist party. The person | | 12 | tortured them is this attorney's partner. They all | | 13 | have their own attorneys. They told me don't ask me | | 14 | or communicate with me about their own financial and | | 15 | personal information. Anything you want to do it's | | 16 | better go through attorneys. | | 17 | This is the doctrine, the thing, my family | | 18 | members told them before they came to New York. I | | 19 | just want to tell you it's the meaning, very similar | | 20 | meanings, but I can't tell you word by word. | | 21 | So I don't want this counsel make any | | 22 | stories about my daughter -- about my daughter's | | 23 | forgery, giving false testimony. That kind of | | 24 | story. |

The last time when we were here with Ms.

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| 1 | Holley and he was making false lies and saying I'm | |----|-------------------------------------------------------| | 2 | using my Twitter account and saying that the judge | | 3 | in New York was communist party and I didn't even | | 4 | have a Twitter account. | | 5 | MR. HARBACH: Just so the record's clear | | 6 | today is the first that I've uttered a word in | | 7 | connection with this litigation in court. So I | | 8 | don't think you're talking about me, sir. | | 9 | THE WITNESS: I was saying last time was | | 10 | from attorney in your office. The prior attorney | | 11 | before you called Andy Morse (ph) and was kicked out | | 12 | by the judge because he was making false claims for | | 13 | five years and was kicked out by the judge. So the | | 14 | law office was always making false claims. | | 15 | MR. BALDIGA: Just answer his question | | 16 | because I can't know whether to object unless you're | | 17 | just trying to answer his question. | | 18 | THE WITNESS: I didn't talk to my family, | | 19 | daughter and wife individually to say the same | | 20 | thing. If I say the same thing, same words, that | | 21 | will be making false story. | | 22 | MR. HARBACH: I understand. | | 23 | THE WITNESS: You cannot use your | | 24 | imagination and put it into my head. This is why | | 25 | the New York South District and the judge was |

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(indiscernible) by them and they give me the wrong sentencing. UNIDENTIFIED: Can you say that last -- THE WITNESS: Because of their false claims, so that's why the judge from the south district of New York, the judge, gave me the wrong sentencing. THE PRIVATE INTERPRETER: And also the interpreter did not interpret fully counsel's instruction to the witness previously about his objection. MS. CLAIBORN: If you want to repeat it, go ahead. MR. BALDIGA: I think you just have to listen to these questions and answer just these questions. MR. HARBACH: Sorry. Counsel will move to a different topic. BY MR. HARBACH: Q Mr. Kwok, Ms. Claiborn asked you today about a \$21 million debt that you owe to Golden Spring. She asked you how much of that 21 million was legal fees and your answer was I think most of it. I'd like to know what you meant by most of it.

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| | Ho Wan Kwok - April 6, 2022 92 | |----|--------------------------------------------------------| | 1 | Did you mean \$11 million or do you mean close to \$21 | | 2 | million. | | 3 | A I don't remember. | | 4 | Q Do you still believe that most of it was | | 5 | for legal fees? | | 6 | A I don't remember. | | 7 | Q You also mentioned the Logan Cheng | | 8 | settlement and that there was money borrowed from | | 9 | Golden Spring in connection with that. | | 10 | A Yes. | | 11 | Q How much money was that loan for? | | 12 | A I don't remember exactly. Probably like | | 13 | 200. Two -- \$300,000. | | 14 | Q What were the terms of that loan from | | 15 | Golden Spring? | | 16 | A I don't remember. | | 17 | Q When Ms. Claiborn asked you if you had | | 18 | ever been to Golden Spring's offices in New York, | | 19 | you said yes. | | 20 | What's the address of those offices? | | 21 | A Yes. | | 22 | Q What is the address of those offices? | | 23 | A 64th Street, 162. | | 24 | Q You also mentioned that the last time you | | 25 | were there was yesterday and that the reason you |

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| | | Ho Wan Kwok - April 6, 2022 | 93 | |----|-----------------|---------------------------------------------------|----| | 1 | | went there was to prepare for today's meeting. | | | 2 | | Who did you meet with there? | | | 3 | A | My attorney. | | | 4 | Q | Did you meet with anyone else besides your | | | 5 | | attorney to prepare for today's meeting while you | | | 6 | | were at the office? | | | 7 | A | I don't know what you mean, the other | | | 8 | people. | | | | 9 | Q | Well, did you meet with anyone who works | | | 10 | | for Golden Spring? | | | 11 | A | Yes, I met Yvonne Wang. | | | 12 | Q | And this was yesterday? | | | 13 | A | Yes, I met her yesterday. | | | 14 | Q | Did you ask some questions of her | | | 15 | yesterday? | | | | 16 | A | No. | | | 17 | Q | And tell me about your conversation with | | | 18 | Ms. Wang? | | | | 19 | A | What do you mean? | | | 20 | Q | Well, I'd like to know what you talked | | | 21 | about with her. | | | | 22 | A | I ask her to arrange the food to eat and | | | 23 | the coffee. | | | | 24 | Q | Is that all? | | | 25 | A | And also we talked about how to abolish | |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 95 of 134 | |---------------|-------------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 94 | | 1 | communist party. | | | 2 | Q | I want to make sure I get this right. I | | 3 | think you said -- | | | 4 | | MR. BALDIGA: Excuse me. Can I hear the | | 5 | last thing again. | | | 6 | | THE WITNESS: We talk about how to abolish | | 7 | communist party. | | | 8 | | MR. BALDIGA: Thank you. | | 9 | Q | Ms. Wang is an officer of Golden Spring, | | 10 | correct? | | | 11 | A | Yes. | | 12 | Q | And you directed her to bring coffee, | | 13 | right? | | | 14 | A | No, I didn't direct her. I'm just hoping | | 15 | | her to bring some coffee. | | 16 | Q | You were hoping or helping? | | 17 | A | Help. | | 18 | Q | You were helping. Because my question to | | 19 | | you was what you talked about with Ms. Wang. And I | | 20 | | thought you said you asked her to bring some coffee | | 21 | | or maybe even told her to bring some coffee. | | 22 | A | No, your attorney office -- you attorney | | 23 | | office making and imagining things again. | | 24 | Q | I'll ask the question again. | | 25 | | MR. BALDIGA: Please ask a question. Don't |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 96 of 134 | |---------------|---------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 95 | | 1 | put words in his mouth. | | 2 | Q What did you discuss with Ms. Wang | | 3 | yesterday? | | 4 | A Do you want me to talk about in detail? I | | 5 | can talk about this for hours. | | 6 | Q Well, no, not if the detail concerns how | | 7 | to overthrow the Chinese Communist Party. So I'll be | | 8 | more precise. | | 9 | A So you don't want us to abolish Chinese | | 10 | Community Party. Our job is to abolish Chinese | | 11 | Communist Party. | | 12 | MR. BALDIGA: Just answer the question. | | 13 | THE WITNESS: You don't have a question. | | 14 | You're just directing something. | | 15 | Q Sometimes I speak in segments to allow the | | 16 | interpreter to translate. | | 17 | MR. BALDIGA: I think it would be helpful | | 18 | if you just ask question and then the witness -- | | 19 | I'll instruct him to answer your questions. That | | 20 | would be helpful. | | 21 | Q Did you discuss with Yvette [sic] | | 22 | yesterday anything related to preparing for the | | 23 | meeting today? | | 24 | A Yes. | | 25 | Q What did you discuss? |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 97 of 134 | |---------------|---------------|------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 96 | | 1 | A | I ask her to bring those documents here. | | 2 | Q | Anything else? | | 3 | A | I don't remember. | | 4 | Q | When was Lamp Capital created? | | 5 | A | I don't know. | | 6 | Q | Why was Lamp Capital created? | | 7 | A | I don't know. | | 8 | Q | Who created Lamp Capital? | | 9 | A | My son. | | 10 | Q | How do you know that? | | 11 | A | Because I borrow money from my son to pay | | 12 | attorney fee. | | | 13 | Q | The question is how do you know that your | | 14 | | son created Lamp Capital? | | 15 | A | Because my son said it. | | 16 | Q | He told you himself. | | 17 | A | Yes. | | 18 | Q | Did he ask for any advice from you about | | 19 | | whether to create Lamp Capital? | | 20 | A | No. | | 21 | Q | Did he ask you your opinion on whether he | | 22 | | should create Lamp Capital? | | 23 | A | No. | | 24 | Q | Did he tell you why he was creating Lamp | | 25 | Capital? | |

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| 1 | A No. | |----|----------------------------------------------------| | 2 | Q When you were talking about your | | 3 | malpractice claim against Boise Schiller, you | | 4 | mentioned someone you kept referring to as he. I'd | | 5 | like to know who that person is? | | 6 | A I don't know what you mean. | | 7 | Q Yes, that was a bad question. I apologize. | | 8 | You stated that there was someone who gave | | 9 | false documents to the court without your | | 10 | permission. That this person threatened your | | 11 | family, that this person threatened you after | | 12 | drinking and that this person brought lots of loss | | 13 | to you and your family, including not providing | | 14 | translated documents before presenting them to the | | 15 | judge. | | 16 | My question is who is that person? | | 17 | A Schiller. The Attorney Schiller. | | 18 | Q So Mr. Schiller of the Boise Schiller law | | 19 | firm. Have I got that right? | | 20 | A Yes. | | 21 | Q Thank you. Do you have an understanding of | | 22 | what business Lamp Capital is engaged in, if any? | | 23 | A No. | | 24 | Q Different subject. You said several times | | 25 | today in connection with your answers that the |

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| | Ho Wan Kwok - April 6, 2022 98 | |----|----------------------------------------------------------| | 1 | people behind me have done certain things. | | 2 | Who are you talking about? | | 3 | A One person behind me, there is a boss | | 4 | called Bruno Wu. He paid the case that -- the rape | | 5 | case from (indiscernible) rape case. Also there is | | 6 | a creditor here and that also was paid by Bruno Wu. | | 7 | That attorney fee was paid by Bruno Wu. And Bruno | | 8 | Wu is also his partner and he invested \$800 million. | | 9 | Bruno Wu's partner is also (indiscernible) previous | | 10 | officer and they were investigating and they | | 11 | combined a partner with them to investigate my case. | | 12 | So April 18, 2017, so this (indiscernible) | | 13 | start suing me, bring the lawsuit. Within this 24 | | 14 | hours Bruno Wu is sending me the red note and they | | 15 | start bringing the lawsuit. | | 16 | MR. HARBACH: Can I stop -- | | 17 | THE WITNESS: The Chinese Communist Party | | 18 | stopped the interview, the VOA interview with me. | | 19 | They happened at the same time. | | 20 | MR. HARBACH: Or I can let him go. | | 21 | THE WITNESS: All the documents made by | | 22 | this attorney firm were all false. They provide a | | 23 | false document to the South District of New York | | 24 | court. They even false claim on my daughter's | | 25 | yacht. The boat is mine. They sought the judge |

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| 1 | from the South District Court and I file the | |----|------------------------------------------------------| | 2 | bankrupt -- personal bankruptcy case twice and the | | 3 | day -- they (indiscernible) twice including Ms. | | 4 | Holley. And Ms. Holley was present. | | 5 | The first time when Ms. Holley was present | | 6 | in the court and they false testified saying -- and | | 7 | they said my daughter was giving false testimony for | | 8 | the Sherry bankruptcy case because my daughter never | | 9 | participated in that case. | | 10 | And Ms. Holley was there, was present the | | 11 | second co date and Ms. Holley was there also. The | | 12 | attorney from the firm was telling the judge and | | 13 | they said that I used the Twitter account to -- and | | 14 | they said on the Twitter and I was saying on the | | 15 | Twitter the south district judge was communist party | | 16 | member. | | 17 | You can see here all the people behind me | | 18 | and one is Bruno Wu and one person paid in many | | 19 | cases -- | | 20 | MR. HARBACH: I'd like to ask another | | 21 | question. | | 22 | BY MR. HARBACH: | | 23 | Q Are you aware one way or the other whether | | 24 | your bankruptcy counsel, the Brown Rudnick law firm, | | 25 | has ever previously represented Bruno Wu? |

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| | Ho Wan Kwok - April 6, 2022 100 | |----|----------------------------------------------------| | 1 | THE OFFICIAL INTERPRETER: Can I take a | | 2 | little break? I just can't concentrate as much. | | 3 | Just too much. Can I take a break? | | 4 | MS. CLAIBORN: Can I ask you to ask that | | 5 | question and then we'll take a break? | | 6 | THE OFFICIAL INTERPRETER: Yes. Can you | | 7 | repeat that question? | | 8 | MR. HARBACH: I'd be happy to. | | 9 | Q Are you aware one way or the other of | | 10 | whether your bankruptcy counsel, the Brown Rudnick | | 11 | law firm, previously represented Bruno Wu? | | 12 | THE OFFICIAL INTERPRETER: Represent | | 13 | somebody else you said? | | 14 | MR. HARBACH: Yes. Bruno Wu. | | 15 | A No. | | 16 | MS. CLAIBORN: I'm going to take a short | | 17 | break. We're going to be back here at 2:45. | | 18 | (Break) | | 19 | MS. CLAIBORN: All right. We are back on | | 20 | the record after a short break. | | 21 | Mr. Harbach, the floor is yours. | | 22 | MR. HARBACH: Thank you. | | 23 | BY MR. HARBACH: | | 24 | Q Ms. Kwok, among the documents in front of | | 25 | you, document 78 filed in this case. |

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Ho Wan Kwok - April 6, 2022 THE OFFICIAL INTERPRETER: Which document? This one? MR. HARBACH: Yes. My apologies. Counsel advises me that your copies are not stamped. Q I'm talking about your official from 106. So my question for you starts on page 9, which contains a heading that says Schedule D, creditors who have claimed (indiscernible) by the property. Are you with me? You checked the box yes. And were directed to Schedule D, so that's where I would like you to flip to, please. And it's at page 18. MR. BALDIGA: What's the title? He can maybe find it better with the title. MR. HARBACH: Okay. It's the little chart that is Schedule D, which is a list of creditors with secured claims. BY MR. HARBACH: Q Mr. Kwok, you'll see that there are five separate entries for Golden Spring New York Limited. The data in each column is identical for all five rows. So my question is why are there five identical entries on this schedule? The question is why are there five

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Ho Wan Kwok - April 6, 2022 identical entries on this schedule? A I don't know what that means five -- Q Well, each row is exactly the same. And I'm just asking why there are five rows with the same information? A I don't know. Q Among that documents that you filed were some specific notes and one of those notes discusses the residence on Taconic Road. MR. HARBACH: And for counsel I'm at document 77, page 4. THE OFFICIAL INTERPRETER: Which page? MR. HARBACH: Page 4. THE OFFICIAL INTERPRETER: 84? MR. HARBACH: No, Page 4. THE OFFICIAL INTERPRETER: Oh, page 4. Okay. BY MR. HARBACH: Q My question really isn't so much about the exact test as it is the substance. So first question, is it true that all expenses related to the Taconic Road House are paid directly by family and family controlled enterprises? A Yes. Q Okay. Which family members?

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| | Ho Wan Kwok - April 6, 2022 103 | |----|-----------------------------------------------------| | 1 | A My wife, sometimes by my son. | | 2 | Q Which family controlled enterprises? | | 3 | A Which country -- my wife. | | 4 | Q Your wife's not an enterprise. I'm trying | | 5 | to ask which family controlled enterprises pay the | | 6 | expenses for the Taconic House? | | 7 | A Greenwich LLC. | | 8 | Q Okay. Incidentally, how do you know that | | 9 | your wife and sometimes you son pay these expenses? | | 10 | A Because I live there. | | 11 | Q Do you observe them pay the expenses? | | 12 | A Yes. | | 13 | Q Is that ever at your request? | | 14 | A I don't remember I request anything. | | 15 | Q Does Greenwich Land LLC -- yes Greenwich | | 16 | Land LLC own any other real estate besides 373 | | 17 | Taconic Road? | | 18 | A I don't know. | | 19 | Q Do you know anything about the property | | 20 | located at 33 Ferncliff in Cos Cob, Connecticut? | | 21 | THE OFFICIAL INTERPRETER: Can you repeat | | 22 | that? | | 23 | MR. HARBACH: Yes. | | 24 | Q 33 Ferncliff in Cos Cob, Connecticut. | | 25 | THE OFFICIAL INTERPRETER: 31, right? |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 105 of 134 | |---------------|--------------------|-------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 104 | | 1 | | MR. HARBACH: No, 33. | | 2 | A | Yes, now I remember it. It's also owned by | | 3 | my wife's company. | | | 4 | Q | That being Greenwich Land? | | 5 | A | Maybe. | | 6 | Q | Do you know? | | 7 | A | I'm not sure. | | 8 | Q | Have you ever been to 33 Ferncliff? | | 9 | A | Yes. | | 10 | Q | How recently? | | 11 | A | No. Not recently. | | 12 | Q | Do you know when Greenwich Land purchased | | 13 | 33 Ferncliff? | | | 14 | A | I don't remember. | | 15 | Q | Do you know approximately how much money | | 16 | it cost? | | | 17 | A | Probably more that \$1 million. | | 18 | Q | Does \$1.37 million sound about right? | | 19 | A | I'm not sure. | | 20 | Q | And does the approximate purchase date of | | 21 | | September, 2019 sound about right to you? | | 22 | A | Not sure. | | 23 | Q | Turning back to 373 Taconic for a moment. | | 24 | | How much was that property purchased for? | | 25 | A | Probably 400 to 500,000. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 106 of 134 | |---------------|--------------------|-------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 105 | | 1 | | THE PRIVATE INTERPRETER: No, no, no. | | 2 | | THE OFFICIAL INTERPRETER: 4 to 5 million. | | 3 | I'm sorry. | | | 4 | Q | Approximate time of purchase of 373 | | 5 | | Taconic, if you know? | | 6 | A | I don't know. | | 7 | Q | Have you ever resided at 33 Ferncliff? | | 8 | A | No. | | 9 | Q | Do you know whether anyone currently lives | | 10 | there? | | | 11 | A | Before there is another comrade maybe, you | | 12 | | know, for disjoined Chinese Communist Party and he | | 13 | was to live there. | | | 14 | Q | How long ago? | | 15 | A | Probably one to two years ago. | | 16 | Q | DO you remember that person's name? | | 17 | A | Yes. | | 18 | Q | What is it? | | 19 | A | Wong Din Gong (ph). | | 20 | Q | Does anyone currently live there, if you | | 21 | know? | | | 22 | A | I don't know. | | 23 | Q | Talking about 373 Taconic, where did the | | 24 | | money come from to purchase that property? | | 25 | A | I don't know. |

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| | | Ho Wan Kwok - April 6, 2022 | 106 | |----|--------------------|-------------------------------------------------|-----| | 1 | Q | Do you know whether the house was | | | 2 | | purchased with cash or financing? | | | 3 | A | I don't know. | | | 4 | Q | Same questions for 33 Ferncliff. Do you | | | 5 | | know where the money came from to purchase that | | | 6 | house? | | | | 7 | A | I heard it was purchased by cash. | | | 8 | Q | From whom -- sorry. From whom did you hear | | | 9 | that? | | | | 10 | A | I don't remember. | | | 11 | Q | Do you know where that money came from? | | | 12 | A | I don't know. | | | 13 | Q | Do you know what Saraca Media Group is? | | | 14 | A | Saraca? | | | 15 | Q | Saraca. | | | 16 | A | Saraca Media Group. I do. | | | 17 | Q | What is Sirraca Media Group? | | | 18 | A | Just Saraca. It's a company. | | | 19 | Q | What kind of company? | | | 20 | A | I'm not sure. | | | 21 | Q | Have you ever had any relationship with | | | 22 | Saraca personally? | | | | 23 | A | No. | | | 24 | Q | Do you know anything about the type of | | | 25 | | business that Saraca conducts? | |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 of 134 | Entered 03/27/23 14:12:10 | Page 108 | |---------------|-----------------|-----------------------------|------------------------------------------------------|----------| | | | Ho Wan Kwok - April 6, 2022 | | 107 | | 1 | A | | I remember they are related to GTV Media | | | 2 | | | platform, or they invested on the GTV Media | | | 3 | platform. | | | | | 4 | Q | How do you know that? | | | | 5 | A | | Because I was their consultant, who owned | | | 6 | the consultant. | | And also I was the GTV host. | And | | 7 | | | also this is one of the input and platform for | | | 8 | | disjoined communist party. | | | | 9 | Q | | When you said you were a consultant a | | | 10 | | | moment ago was that for Saraca or for GTV? | | | 11 | A | GTV. | | | | 12 | Q | | Has Saraca ever been -- ever had the 162 | | | 13 | | | East 64th Street address associated with it? | | | 14 | | THE OFFICIAL INTERPRETER: | Which address? | | | 15 | | Can you repeat that one. | | | | 16 | Q | Yes. | 162 East 64th Street. The question | | | 17 | | | is whether Saraca has ever been associated with that | | | 18 | address? | | | | | 19 | A | I don't know. | | | | 20 | Q | | That is the family office address, | | | 21 | correct? | | | | | 22 | A | It's one of them. | | | | 23 | Q | Where are the other ones? | | | | 24 | A | I don't know. | | | | 25 | Q | | Are there any others in New York City? | |

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| | Ho Wan Kwok - April 6, 2022 108 | |----|-------------------------------------------------------| | 1 | A I just want to clarify. Golden Spring is | | 2 | one of the companies in this building, 162. | | 3 | Q Understood and thank you. | | 4 | We've referred to the family office during | | 5 | your questioning and I just want to be clear. When | | 6 | we talk about the family office are we referring to | | 7 | that address on East 64th Street? | | 8 | A Yes. | | 9 | Q Has GTV ever been associated with the | | 10 | family office address? | | 11 | A I don't know. | | 12 | Q Who owns Saraca? | | 13 | A My son. | | 14 | Q Since when? | | 15 | A I don't know. | | 16 | Q Does Saraca currently exist? | | 17 | A I don't know. | | 18 | Q Do you have any idea how many -- do you | | 19 | know anything about the value of Saraca's assets? | | 20 | A I don't know. | | 21 | Q Do you know anything about payments Saraca | | 22 | has made to GTV? | | 23 | A No, I don't know. | | 24 | Q Has your wife ever told you about any | | 25 | multi-million dollar payments from Saraca to |

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| | | Ho Wan Kwok - April 6, 2022 | 109 | |----|-----------------|------------------------------------------------------|-----| | 1 | Greenwich Land? | | | | 2 | A | I don't know. | | | 3 | Q | You don't know whether he's ever told you | | | 4 | | or you don't know about the payments? | | | 5 | A | She never told me and I don't even know | | | 6 | how much. | | | | 7 | Q | Do you know a company called Ziba Limited, | | | 8 | Z-I-B-A? | | | | 9 | | THE OFFICIAL INTERPRETER: Ziba, Z-I-B-A? | | | 10 | | MR. HARBACH: Yes. | | | 11 | A | I don't know. | | | 12 | Q | I'm sorry if I've already asked this. | | | 13 | | What is the relationship, if any, between Saraca and | | | 14 | GTV? | | | | 15 | A | Saraca is the investor for GTV. | | | 16 | Q | Do you know how much money Saraca invested | | | 17 | in GTV? | | | | 18 | A | I don't know. | | | 19 | Q | When was GTV founded? | | | 20 | A | 2020. Maybe 2019. Not very sure. | | | 21 | Q | Do you know the names of any of the | | | 22 | | officers or directors of Saraca? | | | 23 | A | I don't know. | | | 24 | Q | Do you know whether Yvette Wang is an | | | 25 | | officer or director of Saraca? | |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 111 of 134 | | |---------------|-------------|-------------------------------------------------------------------|-----| | | | Ho Wan Kwok - April 6, 2022 | 110 | | 1 | A | I don't know. | | | 2 | Q | Do you know someone called Hong Chung | | | 3 | Wang? | | | | 4 | A | Yes. | | | 5 | Q | Who is that? | | | 6 | A | He's my partner and also comrade for | | | 7 | | disjoined Communist Party. | | | 8 | Q | Is he a friend of yours? | | | 9 | A | Friend, comrade and a partner. | | | 10 | Q | What do you mean by partner? | | | 11 | A | Because we had a business corporation. | | | 12 | Q | Tell me about that. | | | 13 | A | Well, I don't remember the name of that | | | 14 | company. | It's a company for investigating Communist | | | 15 | | Party in USA doing money laundering and committing | | | 16 | crimes. | | | | 17 | Q | Was it a for profit company? | | | 18 | A | I don't know. | | | 19 | Q | You don't know? | | | 20 | A | I don't know. | | | 21 | Q | What was the name of the company? | | | 22 | A | I don't remember when getting to English. | | | 23 | | I don't remember the name. | | | 24 | Q | Approximately what time frame where you | | | 25 | | partners with Hong Chung Wang in this company? | |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 112 of 134 | |---------------|-------------|-------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 111 | | 1 | A | I don't remember. | | 2 | Q | Within the last three years? | | 3 | A | It must be more than three years ago. | | 4 | Q | More than ten years? | | 5 | A | No. | | 6 | Q | Did Hong Chung Wang ever have any | | 7 | | connection to Saraca? | | 8 | A | I don't know. | | 9 | Q | Was he ever an officer or director of | | 10 | Saraca? | | | 11 | A | I don't know. | | 12 | Q | What does the G in GTV stand for? | | 13 | A | God. The Goal, like in -- G-O-A-L. | | 14 | Q | The English word "goal"? | | 15 | A | Yea. Goal or God. | | 16 | Q | Okay. How long have you known Hong Chong | | 17 | Wang? | | | 18 | A | I don't remember. | | 19 | Q | More than ten years? | | 20 | A | Roughly. | | 21 | Q | And do you still consider him a friend | | 22 | today? | | | 23 | A | Yes. | | 24 | | MR. HARBACH: Just a moment, please. | | 25 | Q | There's been many questions today about |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 | Entered 03/27/23 14:12:10 | Page 113 | |---------------|-------------|----------------|---------------------------|----------| |---------------|-------------|----------------|---------------------------|----------|

| | Ho Wan Kwok - April 6, 2022 112 | |----|------------------------------------------------------| | 1 | Golden Spring funding your living expenses. | | 2 | Is it correct that as far as your living | | 3 | expenses are concerned that none of that is expected | | 4 | to be repaid? | | 5 | A Yes, true. | | 6 | Q And so those monies are not the subject of | | 7 | any formal agreement, correct? | | 8 | A No. | | 9 | Q And those monies essentially then are a | | 10 | gift to you, correct? | | 11 | A Yes. | | 12 | Q What's the Rule of Law Foundation? | | 13 | A What does that mean? | | 14 | Q The question is what is it? | | 15 | THE OFFICIAL INTERPRETER: The Rule of Law | | 16 | Foundation? | | 17 | MR. HARBACH: Yes, sir. | | 18 | THE OFFICIAL INTERPRETER: I didn't get | | 19 | it. Can you ask it another way? | | 20 | Q There's an entity called -- | | 21 | THE OFFICIAL INTERPRETER: Oh. | | 22 | Q -- the Rule of Law Foundation. | | 23 | THE OFFICIAL INTERPRETER: Okay. | | 24 | MR. HARBACH: I'll hopefully save some | | 25 | time by just asking this question instead. |

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 114 of 134 | |---------------|----------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 113 | | 1 | Q Are you familiar with the Rule of Law | | 2 | Foundation? | | 3 | A Yes. | | 4 | Q Were you involved in its establishment? | | 5 | A Yes. | | 6 | Q Did you contribute any money to it when it | | 7 | was formed? | | 8 | A Not myself. | | 9 | Q Did you direct any entity to contribute to | | 10 | the Rule of Law Foundation? | | 11 | A Suggestion in a direct and suggesting any | | 12 | difference -- | | 13 | Q If there was a suggestion, please tell me | | 14 | it was a suggestion. | | 15 | A I didn't direct anybody or order anybody. | | 16 | I just always suggest people to make donations for | | 17 | the Foundation. | | 18 | THE PRIVATE INTERPRETER: As an | | 19 | interpreter, I think that if the witness is asking | | 20 | the interpreter questions, the interpreter should | | 21 | interpret the question asked by the witness instead | | 22 | of answer that question. | | 23 | THE OFFICIAL INTERPRETER: I can answer | | 24 | anything. | | 25 | THE PRIVATE INTERPRETER: The witness said |

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| | Ho Wan Kwok - April 6, 2022 114 | |----|----------------------------------------------------| | 1 | are you talking about the (indiscernible) -- | | 2 | THE OFFICIAL INTERPRETER: That's why I | | 3 | relayed the questions to the attorney. | | 4 | THE PRIVATE INTERPRETER: You answer him | | 5 | yes, and then you say that. | | 6 | THE OFFICIAL INTERPRETER: Oh, for God's | | 7 | sake. I didn't say -- did I miss anything? | | 8 | (Interpretation.) | | 9 | THE OFFICIAL INTERPRETER: Okay. No | | 10 | question. He said no question was not answered. | | 11 | BY MR. HARBACH: | | 12 | Q Did you ever suggested to any of your | | 13 | family members that they donate to the Rule of Law | | 14 | Foundation? | | 15 | A Yes, I did suggest. | | 16 | Q Did any of your family members or the | | 17 | family controlled enterprises contribute money to | | 18 | the Rule of Law Foundation? | | 19 | A Yes. | | 20 | Q How much money? | | 21 | A For cash there is one -- over \$1 million. | | 22 | From Hong Kong, Japan and Mainland -- in | | 23 | China and all combined it should be more than 30 | | 24 | million. | | 25 | Q And just focusing for the moment on |

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| | Ho Wan Kwok - April 6, 2022 115 | |----|----------------------------------------------------| | 1 | contributions from your family at your suggestion. | | 2 | Approximately, how much money is that? | | 3 | A I don't know the details. Because of | | 4 | security reasons they don't want me to know. | | 5 | Q Did you say a moment ago that your family | | 6 | contributed over a million dollars? | | 7 | A One million cash is in New York here. | | 8 | Q When was that? | | 9 | A I don't remember. | | 10 | Q Is the reason -- well, let me ask it this | | 11 | way. Did you suggest an amount to your family | | 12 | members that they should contribute to the Rule of | | 13 | Law Foundation? | | 14 | A I want them to donate the more the better. | | 15 | Q Is that what you told them? | | 16 | A Yes. | | 17 | Q Do you know whether the Rule of Law | | 18 | Foundation is associated with the family office | | 19 | address on 64th Street? | | 20 | A Yes. | | 21 | Q Did you ever make a \$100 million donation | | 22 | to the Rule of Law Foundation in November of 2018? | | 23 | THE OFFICIAL INTERPRETER: Can you repeat | | 24 | that again? | | 25 | Q Did you ever make a \$100 million donation |

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Ho Wan Kwok - April 6, 2022 to the Rule of Law Foundation in November, 2018? A No. In the live stream like I want -- tried to collect the funds, in the live stream show. Q Did you ever -- MR. BALDIGA: Wait. Was that his whole answer? THE OFFICIAL INTERPRETER: Yeah. Something wrong? THE PRIVATE INTERPRETER: Not quite exactly what the witness said. (Indiscernible) broadcasting is okay. Live stream is okay. But collect money -- THE OFFICIAL INTERPRETER: Asking for donation, right? (Interpretation) THE PRIVATE INTERPRETER: Raise -- THE WITNESS: Raising money, raise donations. Yeah, in the live stream broadcast thing, or whatever, you know, asking for donations to -- you know, to raise funds, to raise money. Q Did you ever promise to donate \$1 billion to the Rule of Law Fund? THE OFFICIAL INTERPRETER: 10 billion you said? MR. HARBACH: No, sir. 1 billion.

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| | Ho Wan Kwok - April 6, 2022 117 | |----|-------------------------------------------------------| | 1 | THE OFFICIAL INTERPRETER: Oh, one | | 2 | billion. | | 3 | A I don't remember. I don't remember. | | 4 | Q Do you mean that it's possible that you | | 5 | made that promise? | | 6 | A So we could reach that goal if we combine | | 7 | the organizations all over the world. | | 8 | Q Understand. And it's a simple question. I | | 9 | just don't know the answer. | | 10 | Did you yourself ever promise to donate \$1 | | 11 | billion to the Rule of Law fund? | | 12 | A In the past five years I did the live | | 13 | stream over 5,000 times. Some of the live stream | | 14 | could have reached four or five hours. It's hard | | 15 | for me to remember every sentence I said. | | 16 | Q Well, I understand that, but I'm only | | 17 | asking about one issue. And it is whether you ever | | 18 | promised publicly, or privately or anyhow to donate | | 19 | \$1 billion to the Rule of Law Fund? | | 20 | THE PRIVATE INTERPRETER: He did not say | | 21 | invest. | | 22 | MR. HARBACH: Donate | | 23 | THE OFFICIAL INTERPRETER: Yeah, donate. | | 24 | A I don't remember. | | 25 | Q I'll ask this one one more time. |

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| 1 | Are you saying that it is possible that | |----|--------------------------------------------------------| | 2 | you made such a promise. You just can't be sure? | | 3 | A In front of Ms. Holley I wouldn't say | | 4 | anything is possible but this is a very serious | | 5 | issue. Now they start the scheme again. | | 6 | Q Well, this isn't what did you have for | | 7 | breakfast three days ago. This is did you promise | | 8 | to donate \$1 billion and if the answer is you don't | | 9 | know, that's okay. | | 10 | MR. BALDIGA: I think that's what the | | 11 | answer has been. | | 12 | MR. HARBACH: No, the answer has been I | | 13 | don't remember. | | 14 | MR. BALDIGA: Don't remember. | | 15 | MR. HARBACH: Yes, sir. That's a little | | 16 | different. | | 17 | Q So the answer might be no, but you're not | | 18 | saying no. You're saying you don't remember. | | 19 | A I said it three times, I don't remember. | | 20 | MR. BALDIGA: There's no question -- | | 21 | A Because in the past five years | | 22 | (indiscernible) always making these kind of answers | | 23 | for me so that's why the judge from the South | | 24 | District were fooled by you and you started again -- | | 25 | Q I'll move on. |

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A In the South District court I only met judge 20 seconds. I didn't say one sentence within this five years and I was fined a total about \$300 million because that's what they did. MR. BALDIGA: All right. Let's stop it. Let's wait for a question and we'll answer the question. MR. HARBACH: Bill, I appreciate your patience. I'll move on. MR. BALDIGA: Translate what I said, please. THE OFFICIAL INTERPRETER: Can you repeat that? Everybody's saying at the time. MR. BALDIGA: Ask a question and he'll answer a question. Q Have you made any donations to the Rule of Law Foundation in the last two years? A Myself, right? Q Yes, sir. A No. Q Have you suggested to any of your family that they make donations to the Rule of Law Foundation within the last two years? A I don't remember. Q Would you ever have made a promise to

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| | Ho Wan Kwok - April 6, 2022 120 | |----|-----------------------------------------------------| | 1 | donate \$1 billion to the Rule of Law Foundation if | | 2 | you did not actually have that money? | | 3 | MR. BALDIGA: Objection to form. | | 4 | THE OFFICIAL INTERPRETER: I didn't get | | 5 | it. Can you repeat one more time. | | 6 | Q Would you have ever made a promise to | | 7 | donate \$1 billion to the Rule of Law Foundation if | | 8 | you did not actually have that money. | | 9 | MR. BALDIGA: And I objected. | | 10 | MR. HARBACH: And then Bill objected. | | 11 | THE OFFICIAL INTERPRETER: He said are you | | 12 | -- want to sentencing me to death sentence? | | 13 | Q Approximately how much is the Lady May | | 14 | worth? | | 15 | A I don't know. | | 16 | Q Over the years that you have been aboard | | 17 | the Lady May, approximately how many times have you | | 18 | invited friends to join you? | | 19 | THE OFFICIAL INTERPRETER: Can you repeat | | 20 | that question one more time? | | 21 | MR. HARBACH: Yes. | | 22 | Q Over the years that you had been aboard | | 23 | the Lady May, approximately how many times have you | | 24 | invited friends out to join you? | | 25 | MR. BALDIGA: Hold on. |

# Ho Wan Kwok - April 6, 2022 MR. HARBACH: Sorry, Bill. MR. BALDIGA: David, you have a deposition on the Lady May issues coming up. You can choose today or then. Either one is fine. Case 22-50073 Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 122 of 134

MR. HARBACH: That's a fair point. I'll move on.

MR. BALDIGA: Okay. No question. MR. HARBACH: If I could direct counsel's attention again to document 77. And I want to focus on question 19.

Q Mr. Kwok, let me know when you're read that question. It's no. 19.

(Pause.)

A Finished.

Q Okay. So for the benefit of the record, the question says within ten years before you filed for bankruptcy did you transfer any property to a self settled trust or similar device of which you are a beneficiary?

A No.

Q And that is indeed what you checked on the form. My question for you is if you turn -- if changed the word you to a family member as the beneficiary, what would the answer be? MR. BALDIGA: Objection.

| Case 22-50073 | Doc 1604-22 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 123 of 134 | |---------------|----------------------------------------------------------------------------------| | | Ho Wan Kwok - April 6, 2022 122 | | 1 | A I cannot answer questions with if. | | 2 | Q I'll ask it a different way. | | 3 | MR. HARBACH: And, Jack, I'll ask you to | | 4 | bear with me. | | 5 | Q Within ten years before you filed for | | 6 | bankruptcy did you transfer any property to a self | | 7 | settled trust or similar device of which a member of | | 8 | your family is a beneficiary? | | 9 | A No. | | 10 | Q Sticking with that same document going | | 11 | forward to question 27. Just let me know when | | 12 | you're read it, sir. | | 13 | (Pause.) | | 14 | A Okay. I'm finished. | | 15 | Q So you see there you have checked the box | | 16 | next to the word yes. And then the instructions say | | 17 | check all that apply above and fill in the details | | 18 | below for each business. | | 19 | MR. HARBACH: Do you see where that is, | | 20 | Jack? | | 21 | THE OFFICIAL INTERPRETER: I didn't see | | 22 | that. | | 23 | MR. HARBACH: Next -- Holley can show you. | | 24 | (Pause.) | | 25 | MR. HARBACH: So I was just pointing out |

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| | Ho Wan Kwok - April 6, 2022 123 | |----|--------------------------------------------------------| | 1 | to the witness -- for the benefit of the translator | | 2 | I'll say it again. | | 3 | Q Next to the box that is checked yes, the | | 4 | instructions say check all that apply above and fill | | 5 | in the details below for each business. None of the | | 6 | boxes above is checked and that's my question. | | 7 | Which box or boxes should be checked for | | 8 | each of those three entities that you have listed? | | 9 | A I cannot determine which one. | | 10 | Q Is that something you would need more time | | 11 | to figure out or you just don't know the answer? | | 12 | A I could answer one by one. | | 13 | Q Okay. Let's do that. Let's start with | | 14 | Genever. | | 15 | A Which Genever? | | 16 | Q Well, the one that's listed is Genever | | 17 | Holdings Corporation. | | 18 | Which of those boxes would you check for | | 19 | Genever Holdings Corporation, if any? | | 20 | A It was one time -- it was a member of LLC. | | 21 | The above don't apply and should transfer to no. 12 | | 22 | -- transfer to 12. | | 23 | It used to be an LLC. | | 24 | Q Are you saying that you would check the | | 25 | box for a member of an LLC but it should be in the |

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| | | Ho Wan Kwok - April 6, 2022 | 124 | |----|------------------------------------------------------|-----------------------------------------------|-----| | 1 | past tense? | | | | 2 | A | Yes. Used to be. | | | 3 | Q | Do any of the other boxes apply to your | | | 4 | | relationship to Genever Holdings Corporation? | | | 5 | A | The last row seems like appropriate for | | | 6 | me. I'm not very sure. | | | | 7 | Q | The last row being an owner of at least | | | 8 | five percent of the voting or equity securities of a | | | | 9 | corporation? | | | | 10 | A | I owned 50 percent for a very short period | | | 11 | of time. | | | | 12 | Q | Okay. What about for Shiny Time? | | | 13 | A | Shiny Time already went away. | | | 14 | Q | I understand. When it was in existence, | | | 15 | | which of those boxes was accurate? | | | 16 | A | Number one. | | | 17 | Q | A sole proprietor? | | | 18 | A | Yes. | | | 19 | Q | Any of the others? | | | 20 | A | Not sure. | | | 21 | Q | Okay. What about for Well Origin Limited? | | | 22 | A | It went away. | | | 23 | Q | Okay. Same question though. Which of | | | 24 | those boxes applied when it was in existence? | | | | 25 | A | Number one. | |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 126 of 134 | |---------------|---------------------|-------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 125 | | 1 | Q | Any of the others? | | 2 | A | Not sure. | | 3 | Q | One last point about this question. | | 4 | | For Genever Holdings Corporation the block | | 5 | | for the dates that the business existed is blank. | | 6 | | Do you know what those dates should be? | | 7 | A | 2015. Probably March, April to June, | | 8 | July. | | | 9 | Q | Of which year? | | 10 | A | 2015. | | 11 | Q | So from approximately March or April until | | 12 | | approximately July all in 2015? | | 13 | A | Yes. | | 14 | Q | Okay. And is that the entire duration | | 15 | | that that corporation existed? | | 16 | A | I was in the company for a few months, for | | 17 | | this period of time, a few months and with holding - | | 18 | - in stock holding. | And the company still existed | | 19 | after I left. | | | 20 | Q | I understand. And does it still exist | | 21 | today? | | | 22 | A | I believe it still exists. | | 23 | Q | Okay. In what year did you get married? | | 24 | A | 1918 -- or 1985. | | 25 | Q | What year was your son born? |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 127 of 134 | |---------------|---------------------|-------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 126 | | 1 | A | 1986. | | 2 | Q | And how old are you, sir? | | 3 | A | 54. | | 4 | Q | How old was your son when your family | | 5 | | began working with Uda Property Company? | | 6 | A | 11. Oh, five years -- five years old. | | 7 | Q | And so that would have been in | | 8 | | approximately 1991 that your family began working | | 9 | with Uda? | | | 10 | A | Yes. | | 11 | Q | When was the Henan Uda Hotel completed? | | 12 | A | In 1997. | | 13 | Q | And what about the Uda International Trade | | 14 | Center. | When was it completed? | | 15 | A | At pretty much the same time. | | 16 | Q | In your declaration in this case you | | 17 | | stated that both of those were successful ventures. | | 18 | A | Yes. | | 19 | Q | That allowed your family to start amassing | | 20 | significant wealth. | | | 21 | A | Yes. | | 22 | Q | So recognizing that this is in the early | | 23 | | '90's how much money approximately did those | | 24 | | ventures bring to your family? | | 25 | A | I don't remember. |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 128 of 134 | |---------------|----------------|-------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 127 | | 1 | Q | More than \$50 million? | | 2 | | THE OFFICIAL INTERPRETER: 50 or 15? | | 3 | | MR. HARBACH: 5-0. | | 4 | | THE OFFICIAL INTERPRETER: Oh, okay. | | 5 | A | I don't remember. | | 6 | Q | What about the Pengu Plaza? When was it | | 7 | completed? | | | 8 | A | July 2008. | | 9 | Q | So between the early '90's and 2008 what | | 10 | | other projects of significant did the Guo family | | 11 | | invest in or participate in? | | 12 | | THE OFFICIAL INTERPRETER: Since 1990's to | | 13 | -- | | | 14 | A | Between the early 1990's and 2008. | | 15 | Q | Do you remember any of them? Any of the | | 16 | | significant ventures? | | 17 | A | Beijing Golden Spring. | | 18 | Q | What was that? | | 19 | A | It's a property company. Real estate. | | 20 | | It's a real estate company. | | 21 | Q | Was this a development company or a -- | | 22 | | like a buying and selling agency? | | 23 | A | Developing company. | | 24 | Q | When was the Pangu Plaza project started, | | 25 | approximately? | |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 Page 129 of 134 | |---------------|--------------------|-------------------------------------------------------------------| | | | Ho Wan Kwok - April 6, 2022 128 | | 1 | A | Roughly 1999. | | 2 | Q | Okay. So let's use that as a point in | | 3 | time. | | | 4 | | At the beginning of the Pangu Plaza | | 5 | | project approximately how much had the family | | 6 | amassed in wealth? | | | 7 | | THE PRIVATE INTERPRETER: Ask that | | 8 | question again? | | | 9 | | MR. HARBACH: Sure. | | 10 | Q | As of 1999, which was the beginning of the | | 11 | | Pangu Plaza project, approximately how much wealth | | 12 | | had the family earned or amassed by that time? | | 13 | | THE OFFICIAL INTERPRETER: You're talking | | 14 | about after 1999? | | | 15 | | MR. HARBACH: No, I'm talking about as of | | 16 | 1999? | | | 17 | | THE OFFICIAL INTERPRETER: Oh, as of 1999. | | 18 | Q | How much money had the family made by | | 19 | 1999? | | | 20 | A | I don't remember. | | 21 | Q | More than \$100 million? | | 22 | A | I don't remember. | | 23 | Q | More than \$500 million? | | 24 | A | I don't remember. | | 25 | Q | More than a billion dollars? |

| Case 22-50073 | Doc 1604-22 | Filed 03/27/23 Entered 03/27/23 14:12:10 of 134 | Page 130 | |---------------|-------------|-------------------------------------------------------|----------| | | | Ho Wan Kwok - April 6, 2022 | 129 | | 1 | A | I don't remember. | | | 2 | Q | Were you personally involved in the work | | | 3 | | with Uda Property Company? | | | 4 | A | Yes. | | | 5 | Q | Were you personally involved in the | | | 6 | | development of the Henan Uda Hotel? | | | 7 | A | Yes. | | | 8 | Q | Were you personally involved in the Uda | | | 9 | | International Trade Center in Zhengzhou? | | | 10 | A | Yes. | | | 11 | Q | Were you personally involved in the | | | 12 | | development of the Pengu Plaza? | | | 13 | A | Yes. | | | 14 | Q | Who was in charge of the Beijing Golden | | | 15 | | Spring Real Estate Development firm? | | | 16 | A | A professional group. | | | 17 | Q | Were you a member of that group? | | | 18 | A | At that time I was a consultant. | | | 19 | Q | For Beijing Golden Spring? | | | 20 | A | Yes. | | | 21 | Q | During what time frame was that, | | | 22 | | approximately that you were a consultant for them? | | | 23 | A | After 2000. | | | 24 | Q | After 2000. Okay. | | | 25 | | MS. CLAIBORN: Mr. Harbach, I just want to | |

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| | Ho Wan Kwok - April 6, 2022 130 | |----|------------------------------------------------------| | 1 | note that it is 4:18 and I know we've had a long day | | 2 | -- and I wanted to give -- I apologize for | | 3 | interrupting you, first of all. | | 4 | MR. HARBACH: That's all right. | | 5 | MS. CLAIBORN: But I wanted to give | | 6 | counsel for the committee a chance to ask a few | | 7 | questions today before we conclude. | | 8 | MR. HARBACH: Of course. Sure. | | 9 | MR. STAFSTROM: I'll be very brief. | | 10 | EXAMINATION BY MR. STAFSTROM: | | 11 | Q I noticed your hair is very short. I like | | 12 | it. Have you gotten a haircut recently? | | 13 | A Yes. I had a haircut. | | 14 | Q Where did you get it cut? | | 15 | A My wife. | | 16 | Q Oh, your wife. Okay. | | 17 | Does she always cut your hair? | | 18 | A After the virus until now. | | 19 | Q Okay. All right. I have no further | | 20 | questions then. | | 21 | MS. CLAIBORN: I'm going to put the | | 22 | recording on pause while we work on selecting a new | | 23 | date. | | 24 | (Off the record.) | | 25 | MS. CLAIBORN: We're back on the record |

| | of 134 | | | |----|-----------------------------|---------------------------------------------|--------| | | Ho Wan Kwok - April 6, 2022 | | 131 | | 1 | after a short break. | We have selected a continuance | | | 2 | | date of April 29th, beginning at 10:00 a.m. | We are | | 3 | concluded for today. | Thank you. | | | 4 | (Meeting adjourned.) | | | | 5 | | | | | 6 | | | | | 7 | | | | | 8 | | | | | 9 | | | | | 10 | | | | | 11 | | | | | 12 | | | | | 13 | | | | | 14 | | | | | 15 | | | | | 16 | | | | | 17 | | | | | 18 | | | | | 19 | | | | | 20 | | | | | 21 | | | | | 22 | | | | | 23 | | | | | 24 | | | | | | | | |

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I, CHRISTINE FIORE, court-approved transcriber and certified electronic reporter and transcriber, certify that the foregoing is a correct transcript from the official electronic sound recording of the proceedings in the above-entitled matter.

9 April 15, 2022

11 Transcriber

10 Christine Fiore, CERT

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| | | | Ho Wan Kwok - April 6, 2022 | | 133 | |----|------------------------------|--|-----------------------------|------|-----| | 1 | | | INDEX | | | | 2 | | | | | | | 3 | | | | Page | | | 4 | Examination by Ms. Claiborn | | | 6 | | | 5 | Examination by Mr. Wolman | | | 71 | | | 6 | Examination by Mr. Harbach | | | 80 | | | 7 | Examination by Mr. Stafstrom | | | 130 | | | 8 | | | | | | | 9 | | | | | | | 10 | | | | | | | 11 | | | | | | | 12 | | | | | | | 13 | | | | | | | 14 | | | | | | | 15 | | | | | | | 16 | | | | | | | 17 | | | | | | | 18 | | | | | | | 19 | | | | | | | 20 | | | | | | | 21 | | | | | | | 22 | | | | | | | 23 | | | | | | | 24 | | | | | | | 25 | | | | | |