--- type: court_doc id: "court_ctb_2032_29" court: "CTB" case_no: "22-50073" doc_number: 2032 doc_type: "EXHIBIT" filed_date: "2023-07-25" lang: "en" machine_translated: false url: "https://mubeitech.com/en/court/court_ctb_2032_29" json_url: "https://mubeitech.com/api/court/court_ctb_2032_29" --- # Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #2032-29 Exhibit 29 > 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: Christine Fiore, CERT Fiore Reporting and Transcription Service, Inc. 4 Research Drive, Suite 402 Shelton, CT 06484 (203)929-9992 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 For the U.S. Trustee:　HOLLEY E. CLAIBORN, ESQ. STEVEN MACKEY, ESQ. Office of the U.S. Trustee 150 State Street New Haven, CT For Logan Cheng, Creditor:　JAY MARSHALL WOLMAN, ESQ. Randazza Legal Group 100 Pearl Street, 14th Floor Hartford, CT 06103 For Pacific Alliance Asia Opportunity Fund, LP, Creditors:　DAVID V. HARBACH, II, ESQ. O'Melveny & Myers, LLP 1625 I Street NW Washington, DC STUART SARNOFF, ESQ. MAKENZIE RUSSO O'Melveny & Myers, LLP Times Square Tower 7 Times Square New York, NY ANNECCA SMITH, ESQ. Robinson and Cole 280 Trumbull Street Hartford, CT For Bruno Wu, Weican Meng and Rui Ma, Creditors:　KRISTEN MAYHEW, ESQ. McElroy, Deutsch, Mulvaney & Carpenter One State Street Hartford, CT For the Official Committee of Unsecured Creditors:　STEVEN STAFSTROM, ESQ. Pullman & Comley 850 Main Street Bridgeport, CT 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 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 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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? of 134 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 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 12 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 of 134 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 16 Ho Wan Kwok - April 6, 2022 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 of 134 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 of 134 Ho Wan Kwok - April 6, 2022 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. of 134 Ho Wan Kwok - April 6, 2022 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 of 134 Ho Wan Kwok - April 6, 2022 between Mr. Kwok's personal translator so that we have an official record where the person asking the question is me, it's being officially translated, and Mr. Kwok is giving the answers, and that also is being officially translated. MR. BALDIGA: But, Holley, the problem with that is the witness doesn't know whether Jeff's English report is in fact accurate. You can't leave it up to the witness. That's why we have a check interpreter. If he spoke English, then we wouldn't need any interpreters. He can't do that. MS. CLAIBORN: I think as a practical matter, Mr. Kwok speaks enough English to know whether or not he's answered his question. MR. BALDIGA: No, he doesn't. I object. MS. CLAIBORN: Well, I -- I think that that has been what I have seen from my own personal experience. That said, we're going to try and do the best we can -- MR. BALDIGA: I agree. MS. CLAIBORN: -- and we'll see where we go. MR. BALDIGA: Okay. MS. CLAIBORN: Okay? Case 22-50073　Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 1　BY MS. CLAIBORN: 2　Q So back to questions and answers. Mr. 3　Kwok, do you own an interest in Genever Holdings 4　Corporation? 5　A I just have -- in reality, I don't, but I 6　just held -- I just represent my family to hold some 7　interest. 8　Q Is anyone authorized to act on behalf of 9　Genever Holdings Corporation aside from you? 10　A My son. 11　Q Is there a document that memorializes your 12　ownership interest, whatever it is, in Genever 13　Holdings Corporation? 14　MR. BALDIGA: Objection. You -- you may 15　answer. 16　THE WITNESS: No. 17　THE PRIVATE INTERPRETER: Ms. Holley, can 18　I -- first of all, the last time that -- when he was 19　saying -- instructing the witness about his 20　testimony, what should it be, I don't think the 21　interpreter -- the official interpreter interpreted 22　your instruction. He is telling the witness what he 23　should be doing, but not what you were saying. 24　And then, now that the witness is saying 25　that he asked the interpreter twice that -- you were of 134 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 24 Ho Wan Kwok - April 6, 2022 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 Ho Wan Kwok - April 6, 2022 of 134 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 of 134 Ho Wan Kwok - April 6, 2022 -- MR. BALDIGA: Right. He also have to interpret for the witness what I say. MS. CLAIBORN: You haven't said anything yet and he's going to ask him to repeat his answers so then he's going to translate, and then we can have whatever discussion you want to have. THE PRIVATE INTERPRETER: The counsel raised objection. The interpreter did not interpret the objection. MS. CLAIBORN: I can happily repeat the question, but we are not going to get anywhere today in a meaningful fashion if people are interrupting on basic questions. MR. BALDIGA: No, I didn't interrupt, but -- MS. CLAIBORN: So let me try again. MR. BALDIGA: Okay. But hold on. If I object or if I say anything else, that has to be interpreted. MS. CLAIBORN: You're not waiting for space to interpret. So, Mr. Jeff, can you interpret that exchange that just happened? THE OFFICIAL INTERPRETER: Okay. I don't know. It's just too much interruption. Case 22-50073　Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 of 134 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 of 134　Entered 07/25/23 13:27:53　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 2032-29 Filed 07/25/23 of 134　Entered 07/25/23 13:27:53 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 of 134 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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. Case 22-50073　Doc 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 Case 22-50073 Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53　Page 39 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 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 Ho Wan Kwok - April 6, 2022 of 134 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 45 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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. of 134 Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 48 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. Case 22-50073　Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 51 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 of 134　Entered 07/25/23 13:27:53　Page 53 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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. Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 55 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 58 Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 59 Ho Wan Kwok - April 6, 2022 of 134 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? Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 60 Ho Wan Kwok - April 6, 2022 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? Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 61 of 134 Ho Wan Kwok - April 6, 2022 A No. MR. BALDIGA: Excuse me. Holley, I'm not sure if you're going to come back to it, but there is a reference to the \$12,000. MS. CLAIBORN: I did see that. MR. BALDIGA: Oh, you said he didn't disclose it. MS. CLAIBORN: He did not. It's not in response to the questions on Schedule A-B. MR. BALDIGA: It's right there. MS. CLAIBORN: We can disagree about whether or not it's disclosed, but it's my position that it's not disclosed. I understand you might take a different position. BY MS. CLAIBORN: Q Mr. Kwok, do you own any interest in a company called Ace Decade Holdings Limited? A Yes. Q What is the nature of your ownership interest in Ace Decade Holdings Limited? A So I have the interest and ask for UBS to pay back \$500 million. That kind of interest. Q Are you the only legal owner of Ace Decade Holdings Limited? THE OFFICIAL INTERPRETER: Are you the Case 22-50073　Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 -- of 134 Ho Wan Kwok - April 6, 2022 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. Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 64 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 of 134 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 1　THE PRIVATE INTERPRETER: 21 million. 2　THE WITNESS: 21 million. 21 million and 3　plus now. Probably it's about 300 million. 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 of 134 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 70 Ho Wan Kwok - April 6, 2022 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. Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 71 Ho Wan Kwok - April 6, 2022 of 134 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 of 134　Entered 07/25/23 13:27:53　Page 72 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. 25　Q　Are you referring to the Securities and Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 73 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 74 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 75 Ho Wan Kwok - April 6, 2022 1　by question basis. 2　MR. WOLMAN: And this question, will you 3　maintain the instruction? 4　Mr. Kwok, are you refusing to answer my 5　question? 6　THE WITNESS: Yes. 7　MR. WOLMAN: And on what basis are you 8　refusing to answer my question? 9　MR. BALDIGA: On the basis of instruction 10　from counsel on account of attorney/client 11　privilege. 12　THE WITNESS: Because I can't answer the 13　question because of the privilege between the 14　attorney and me. 15　BY MR. WOLMAN: 16　Q Have you been formally charged by the 17　Securities and Exchange Commission? 18　A No. 19　Q Has the Securities and Exchange Commission 20　closed its investigation of you? 21　MR. BALDIGA: I have to ask again, you can 22　answer that yes or no, if you know. 23　A No. 24　Q Has the Securities and Exchange Commission 25　brought any charges against GTV? Case 22-50073　Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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. Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 77 of 134 Ho Wan Kwok - April 6, 2022 A I don't 100 percent live in Connecticut, but sometimes I live in New York also. Q When did you start living in Connecticut more than 50 percent of the time? A Since March, 2020. Q You had some assets you claim seized by China, correct? A It's not mine. It's from my family. It's my family's. Q Have you ever had assets seized by China? A You're talking about under my name? Q Yes. A No. Q All right. In 2010, what was your personal net worth? A No. Q That wasn't a yes or no question. THE OFFICIAL INTERPRETER: Can I repeat your question again? MR. WOLMAN: Yes. Q In 2010 what was your personal net worth? A I didn't have any property. Q Have you ever had property in your name over \$1 million and by that I include where you owned an interest in a company that interest, of 134 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? Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 79 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 of 134 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? Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 82 Ho Wan Kwok - April 6, 2022 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. Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 83 Ho Wan Kwok - April 6, 2022 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 of 134 Ho Wan Kwok - April 6, 2022 1　question about credit cards and debit cards. Do you 2　have access to any credit cards or debit cards, 3　whether or not they are yours? 4　A I don't understand the difference what he 5　means, access like if I use it myself or if I have 6　somebody else use it. 7　Q Well, let's take those one at a time. 8　Let's begin with using it yourself. Has any member 9　of your family ever provided you a credit card or a 10　credit card number to use for yourself? 11　A I never used. 12　Q The other example you mentioned was 13　perhaps a member of your family using a credit card 14　on your behalf. Is that something that has 15　happened? 16　A What do you mean represent me to use? 17　Q I'm asking about whether to your knowledge 18　any member of your family has ever used a credit 19　card or a debit card to purchase things for you? 20　A My son, my daughter, my wife. They all 21　have credit card to buy things for me. 22　THE PRIVATE INTERPRETER: The witness did 23　not say that, use the credit card to buy things for 24　me. The witness said that my son, my wife bought 25　things for me. Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 85 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Page 86 of 134 Case 22-50073　Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 of 134 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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. 25　The last time when we were here with Ms. of 134 Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 92 Ho Wan Kwok - April 6, 2022 (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. Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 93 Ho Wan Kwok - April 6, 2022 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 of 134 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 of 134　Entered 07/25/23 13:27:53　Page 96 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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? Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 98 Ho Wan Kwok - April 6, 2022 of 134 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 of 134 Ho Wan Kwok - April 6, 2022 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 Ho Wan Kwok - April 6, 2022 of 134 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? of 134 Ho Wan Kwok - April 6, 2022 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. of 134 Ho Wan Kwok - April 6, 2022 1　THE OFFICIAL INTERPRETER: Which document? 2　This one? 3　MR. HARBACH: Yes. My apologies. Counsel 4　advises me that your copies are not stamped. 5　Q I'm talking about your official from 106. 6　So my question for you starts on page 9, which 7　contains a heading that says Schedule D, creditors 8　who have claimed (indiscernible) by the property. 9　Are you with me? 10　You checked the box yes. And were 11　directed to Schedule D, so that's where I would like 12　you to flip to, please. And it's at page 18. 13　MR. BALDIGA: What's the title? He can 14　maybe find it better with the title. 15　MR. HARBACH: Okay. It's the little chart 16　that is Schedule D, which is a list of creditors 17　with secured claims. 18　BY MR. HARBACH: 19　Q Mr. Kwok, you'll see that there are five 20　separate entries for Golden Spring New York Limited. 21　The data in each column is identical for all five 22　rows. 23　So my question is why are there five 24　identical entries on this schedule? 25　The question is why are there five of 134 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? Case 22-50073　Doc 2032-29　Filed 07/25/23 of 134　Entered 07/25/23 13:27:53　Page 104 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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. Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 107 of 134 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? Ho Wan Kwok - April 6, 2022 A I remember they are related to GTV Media platform, or they invested on the GTV Media platform. Q How do you know that? A Because I was their consultant, who owned the consultant. And also I was the GTV host. And also this is one of the input and platform for disjoined communist party. Q When you said you were a consultant a moment ago was that for Saraca or for GTV? A GTV. Q Has Saraca ever been -- ever had the 162 East 64th Street address associated with it? THE OFFICIAL INTERPRETER: Which address? Can you repeat that one. Q Yes. 162 East 64th Street. The question is whether Saraca has ever been associated with that address? A I don't know. Q That is the family office address, correct? A It's one of them. Q Where are the other ones? A I don't know. Q Are there any others in New York City? Case 22-50073 Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Page 108 of 134 of 134 Ho Wan Kwok - April 6, 2022 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 Case 22-50073 Doc 2032-29 Filed 07/25/23　Entered 07/25/23 13:27:53　Page 110 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 Ho Wan Kwok - April 6, 2022 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 of 134 Ho Wan Kwok - April 6, 2022 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 of 134 Ho Wan Kwok - April 6, 2022 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 of 134 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. of 134 Ho Wan Kwok - April 6, 2022 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. Ho Wan Kwok - April 6, 2022 of 134 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. of 134 Ho Wan Kwok - April 6, 2022 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. Fiore Reporting and Transcription Service, Inc. Q Would you ever have made a promise to of 134 Ho Wan Kwok - April 6, 2022 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. 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 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Page 122 of 134 Case 22-50073　Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 of 134 Ho Wan Kwok - April 6, 2022 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 Ho Wan Kwok - April 6, 2022 of 134 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 Ho Wan Kwok - April 6, 2022 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 2032-29　Filed 07/25/23 Entered 07/25/23 13:27:53 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 of 134 Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29 Filed 07/25/23 Entered 07/25/23 13:27:53 of 134　Page 132 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.) Ho Wan Kwok - April 6, 2022 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 Case 22-50073　Doc 2032-29　Filed 07/25/23　Entered 07/25/23 13:27:53　Page 134 Ho Wan Kwok - April 6, 2022　133 1　INDEX 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