Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #2292-36

Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 2 of 142 MEI GUO IN RE: HO WAN KWOK, ET AL., September 13, 2023 1

2 Wednesday, September 13, 2023 3 10:00 a.m. 6 REMOTE Deposition of MEI GUO, held VIA ZOOM, before LISA M. MURACO, a Notary Public of the State of New York, Florida, and Massachusetts. IN RE: HO WAN KWOK, ET AL., 800.211.DEPO (3376)

1 2 A P P E A R A N C E S: 3 (REMOTE) 4 5 PAUL HASTINGS 6 Attorneys for Movant and Cross-Respondent 7 Mr. Luc A. Despins, Chapter 11 Trustee for 8 the Estate of Mr. Ho Wan Kwok 9 200 Park Avenue 10 New York NY 10166 11 BY: AVRAM LUFT, ESQ. 12 Aviluft@paulhastings.com 13 NICHOLAS BASSETT, ESQ. 14 Nicholasbassett@paulhastings.com 15 EZRA SUTTON, ESQ. 16 Ezrasutton@paulhastings.com 17 DOUGLASS BARRON, ESQ. 18 Douglassbarron@paulhastings.com 19 LUYI SONG, ESQ. 20 Luyisong@paulhastings.com 21 22 23 24 25

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1 2 A P P E A R A N C E S: 3 (REMOTE) 4 5 MEISTER SEELIG & FEIN 6 Attorneys for Defendants Greenwich LLC and 7 Hing Chi Ngok 8 125 Park Avenue 9 7th Floor 10 New York, NY 10017 11 BY: AUSTIN KIM, ESQ. 12 Adk@msf-law.com 13 14 15 DAY PITNEY LLP 16 Attorneys for the Witness 17 One Stamford Plaza, 263 18 Tresser Blvd 19 7th Floor 20 Stamford, CT 06901 21 BY: STANLEY A. TWARDY, ESQ. 22 Satwardy@daypitney.com 23 24 25 IN RE: HO WAN KWOK, ET AL., 4

A P P E A R A N C E S: (REMOTE) 6 CHIESA SHAHINIAN & GIANTOMASI 7 Attorneys for Witness 8 One Boland Drive 9 West Orange NJ 07052 10 BY: LEE VARTAN, ESQ. 11 Lvartan@csglaw.com 12 MELISSA WERNICK, ESQ. Also Present: Echo, Mandarin Interpreter IN RE: HO WAN KWOK, ET AL., 800.211.DEPO (3376) Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 7 of

4 respective parties herein, that filing and 5 sealing be and the same are hereby waived.

7 that all objections, except as to the form 8 of the question, shall be reserved to the 9 time of the trial.

11 that the within deposition may be sworn to 12 and signed before any officer authorized

14 force and effect as if signed and sworn 15 to before the Court.

2 E C H O, was duly sworn to interpret the 3 questions from English into Mandarin, and the 4 answers from Mandarin into English.

6 duly sworn by a Notary Public, was examined and 7 testified through the interpreter as follows: 8 MR. LUFT: Thank you.

9 do appearances or do we have them on the 10 record already? 11 THE COURT REPORTER:

12 the record already, but if counsel wants to 13 do them, it's fine. 14 MR. LUFT: That's fine with me.

16 MR. LUFT: 17 Q. Good morning, Ms. Guo. How are you? 18 A. I am quite good. Thank you. 19 Q. Good.

20 before, so I know you are familiar with this, 21 but if you'll bear with me, let's just go over 22 a couple of basics for today. 23 A. Okay. 24 Q.

25 the counsel for the parties in this case prior

1 M. GUO 2 to your deposition that you intend to assert 3 your Fifth Amendment rights to all substantive 4 questions. 5 Is that your understanding of your 6 intention for today? 7 A. Yes. 8 Q. That's fine. 9 But just as we had at the court 10 hearing in August, I need to make my record. 11 So I'm still going to need to ask you a series 12 of questions, after which your counsel, if 13 intends to, will instruct you to assert the 14 Fifth, or you can just assert your Fifth 15 Amendment rights, and then we can move on. 16 Do you understand that will be the 17 process today then? 18 A. I understand. 19 Q. And you understand that you are 20 testifying under oath today? 21 A. Yes. 22 Q. Whether it's answering a question or 23 asserting your Fifth Amendment rights, you have 24 an obligation to testify truthfully, correct. 25 Do you understand that? IN RE: HO WAN KWOK, ET AL., 8

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2 A. I understand. 3 Q.

4 understand one of my questions, will you let me 5 know? 6 A. I will. 7 Q.

8 understanding that if you don't let me know 9 that you don't understand one of my question, 10 it's fair for me to assume that you do 11 understand it? 12 A. Yes. 13 Q.

14 prepare for your deposition today? 15 A. Fifth Amendment. 16 Q.

17 question.

19 not offer truthful testimony today? 20 A. No. 21 Q.

22 prepare for your deposition today? 23 A. Fifth Amendment. 24 Q.

25 here today?

1 M. GUO 2 A. Lee Vartan and Stanley Twardy, 3 Hearty, Twardy. 4 THE INTERPRETER: Sorry, sir. 5 MR. LUFT: We know Stan's name. 6 We're okay. 7 Lisa, just so you know, the 8 realtime, it's not working for some reason. 9 (Discussion held off the record.) 10 BY MR. LUFT: 11 Q. I think my last question was you 12 told me who was representing you. 13 Ms. Guo, have you ever spoken with 14 Austin Kim before today? 15 MR. KIM: I want to interject here 16 for one second. To the extent that you are 17 asking if a conversation ever happened as a 18 yes, no, I don't have an objection to that. 19 MR. LUFT: That's what I'm asking. 20 I'm just -- it's yes, no, have you ever 21 spoken to Austin Kim. 22 MR. KIM: If it's just a yes, no, 23 then I don't have an objection to that. To 24 the extent that you are getting into any 25 substance, if you are, then I'll raise a IN RE: HO WAN KWOK, ET AL., 10

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1 M. GUO 2 separate objection once you ask that 3 question. 4 MR. LUFT: My question right now is 5 just that she's ever spoken to you before 6 today. 7 A. The answer is Fifth Amendment. 8 Q. I'm not asking about any substance. 9 I just want to know if you've ever spoken with 10 Mr. Kim, who is counsel for the defendants, 11 prior to today? 12 MR. TWARDY: Objection. Asked and 13 answered. She's already invoked. 14 MR. LUFT: I don't think that's a 15 reasonable invocation of the Fifth 16 Amendment. 17 MR. KIM: You can certainly make 18 application to the court. 19 MR. LUFT: Mr. Kim? 20 BY MR. LUFT: 21 Q. Have you ever spoken with Mr. Kim's 22 partner Chris Major prior to today? 23 A. Fifth Amendment. 24 Q. Have you ever been represented by 25 Mr. Kim, Mr. Major, and their law firm? IN RE: HO WAN KWOK, ET AL., 11

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2 A. Fifth Amendment. 3 Q.

4 spoken to Mr. Kim about prior to today? 5 MR. KIM:

6 for just one second here.

7 form and also instruct the witness to the 8 extent that she was acting in the capacity

12 witness is free to raise her own objection 13 as well. 14 MR. VARTAN:

15 in the objection. 16 A. The answer is Fifth Amendment. 17 MR. LUFT:

18 understand your objection.

20 at meetings you've been at before? 21 MR. KIM:

22 today. My objection is clear.

23 record, and the witness has raised her own 24 objection as well.

25 MR. LUFT: No, Austin, come on.

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2 That's not reasonable.

3 objection based on the idea that she may 4 have been a translator.

5 I've ever heard of that. And that's okay. 6 But I would like to understand.

7 me she's been a translator, then you can 8 explain who she's been a translator for, 9 then I'll understand it.

10 there and make objections and say, But I 11 won't tell you what's that about.

12 think you can do that. 13 MR. KIM: Okay.

14 objection. It's on the record.

16 objection is, and we are going to stand by 17 it. 18 MR. LUFT:

19 not clear.

20 extent she's been a translator, but she's

22 translator.

24 understand how you can give an instruction 25 not to answer based on being a translator

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2 if there's no foundation that she's ever

4 translator for. 5 MR. KIM:

7 MR. LUFT:

8 parameters.

9 said or anything else.

10 translator works with privilege.

11 have to at least establish that she's been 12 a translator.

14 translator for a meeting, that's fine.

15 to just throw it out there as if -- and 16 give an instruction not to answer, I don't 17 think is proper.

18 understand, Austin, what's going on. 19 MR. KIM: That's fine.

20 can ask the deponent who is sitting here to 21 be -- to answer your questions, and so -- 22 MR. LUFT:

24 MR. KIM: -- Ms. Guo is here.

25 can ask her the question.

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2 objection. We stand by it.

3 proper objection.

4 fine.

5 that's our objection, and I'm not here to 6 answer questions.

8 MR. LUFT:

9 duties of candor and to have a good faith 10 basis upon which to object.

11 form objections is to allow the other 12 attorney to understand an issue so that we 13 can have a clear record.

14 basically say I'm not going to tell you

16 especially when the witness is taking the 17 Fifth onto these questions, I think is 18 unreasonable.

19 certainly don't understand it, because if

21 understand it and I'll not try to delve 22 into privileged information, but, you know, 23 if you are going to tell me that no -- 24 despite all that and no argument to the 25 contrary, you're just going to stand on the

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2 idea that you don't have to say anything,

7 MR. KIM:

8 mischaracterization of what I just said. 9 Avi, that's a complete mischaracterization. 10 I gave you the explicit and express basis 11 for the instruction.

12 into the details of what was discussed. 13 I'm not going to get any details and answer 14 your question. I'm not the deponent. 15 We're here for Ms. Guo's deposition. 16 You can ask the witness and she will answer 17 as she deems fit. That's the objection. 18 MR. LUFT: Fine. Okay.

19 will do it your way, Austin. 20 BY MR. LUFT: 21 Q.

22 you answers to be stated at this deposition? 23 MR. VARTAN: Objection. 24 A. Fifth Amendment. 25 Q.

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2 Mr. Austin -- Mr. Kim and Mr. Major to discuss 3 strategy for what to say at this deposition? 4 MR. KIM: Objection. Form. 5 MR. VARTAN: Objection. 6 A. Fifth Amendment. 7 Q.

8 what answers you needed to give today to help 9 your mother in this lawsuit? 10 MR. VARTAN: Same objection. 11 MR. KIM: Objection to form. 12 A. No. 13 Q. All right.

15 meetings with -- that Mr. Kim and Mr. Major 16 have been at? 17 MR. VARTAN: Objection. 18 MR. KIM: Objection to form.

19 and answered. 20 A. Fifth Amendment. 21 Q.

22 that certain answers would be more helpful to 23 your mom's case? 24 MR. VARTAN: Objection to form. 25 MR. KIM: Objection.

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1 M. GUO 2 answered. 3 A. Fifth Amendment. 4 Q. Please tell me everything that 5 Mr. Major and Mr. Kim have told you at meetings 6 that you've attended with them prior to today? 7 MR. KIM: Objection. Asked and 8 answered. 9 MR. VARTAN: Objection. 10 A. Fifth Amendment. 11 Q. Have you been at meetings with 12 Mr. Kim and Mr. Major where they have discussed 13 the strategy for Greenwich Land and your wife 14 Hing Chi Ngok -- 15 MR. VARTAN: Objection. 16 BY MR. LUFT: 17 Q. Sorry. Your mother. 18 MR. KIM: Objection to form. Asked 19 and answered. 20 I repeat the same advisement to the 21 witness not to answer on basis of 22 privilege, and the witness can answer and 23 invoke her own privilege. 24 MR. LUFT: Sorry. What privilege 25 are you referring to, Austin? IN RE: HO WAN KWOK, ET AL., 18

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2 MR. KIM:

3 our objection pretty clearly.

4 you are not satisfied with it, which is 5 fine. 6 MR. LUFT: No, no, no.

9 MR. KIM: -- it's a valid objection. 10 We've raised it on the record. 11 MR. LUFT:

12 what privilege are you invoking about a 13 conversation between you and her? 14 MR. KIM:

15 the very beginning of this deposition, to 16 the extent that there were interpretation 17 services provided, then that would be 18 covered by privilege.

19 aware of that.

21 MR. LUFT:

22 interpretation privilege.

24 MR. LUFT:

25 no interpretation -- anyone's testified

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1 M. GUO 2 there's been any interpretation done. 3 So -- 4 MR. KIM: Well, you can ask the 5 witness and the witness will provide 6 answers. 7 MR. LUFT: I did. 8 MR. KIM: Okay. I'm not here to be 9 deposed and answer your questions. The 10 witness is here to be deposed and answer 11 your questions. So you can ask the 12 witness, and we can raise our objections. 13 MR. LUFT: I think it's completely 14 improper, Austin. You won't even tell 15 me -- is she your client? 16 MR. KIM: You can ask the witness 17 your questions. 18 MR. LUFT: Let the record reflect 19 and Mr. Kim will not disclose whether or 20 not Ms. Guo is his client or not. 21 MR. KIM: That's absolutely 22 improper. The witness is here to answer 23 questions. The trustee has noticed that 24 this -- today's deposition is for Ms. Guo's 25 deposition, and so counsel should direct

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1 M. GUO 2 his questions to the deponent. 3 This is not a question-and-answer 4 session for the general group. It's for 5 the witness that's being -- has been 6 noticed for today. 7 MR. LUFT: Okay. 8 BY MR. LUFT: 9 Q. Ms. Guo, how many times have you met 10 with Mr. Kim and Mr. Major before today? 11 MR. VARTAN: Objection. Asked and 12 answered. 13 MR. KIM: Objection. Asked and 14 answered. 15 A. Fifth Amendment. 16 Q. Ms. Guo, did Mr. Major and Mr. Kim 17 tell you that it was in your personal interest 18 for your mom and Greenwich Land to succeed in 19 this litigation? 20 MR. VARTAN: Objection. 21 MR. KIM: Objection. Asked and 22 answered. I mean, Avi, you are asking the 23 same questions a hundred different times. 24 I think this is getting -- this is 25 getting -- IN RE: HO WAN KWOK, ET AL., 21

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1 M. GUO 2 MR. LUFT: Austin, stop. 3 MR. KIM: This is getting to the 4 point of harassing the witness, but, you 5 know, that's your call. 6 MR. LUFT: I can't even tell if you 7 are represent her or not, but my question 8 is a new question -- 9 (Multiple speakers.) 10 MR. KIM: You are asking questions 11 and my name happens to be in every single 12 question you're asking, so I think it's 13 fair -- 14 MR. LUFT: Please stop. 15 MR. KIM: -- for me to interject. 16 MR. LUFT: Please stop. 17 BY MR. LUFT: 18 Q. You can answer my question. 19 MR. VARTAN: Same objection. 20 THE INTERPRETER: Allow the 21 interpreter to interpret the question. 22 MR. VARTAN: Sorry. Very good. 23 THE INTERPRETER: Thank you, sir. 24 A. Fifth Amendment. 25 Q. Okay. IN RE: HO WAN KWOK, ET AL., 22

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1 M. GUO 2 Other than Mr. Major and Mr. Kim, 3 who else have you met with to prepare for your 4 deposition today? 5 MR. VARTAN: Objection. 6 A. Fifth Amendment. 7 Q. Ms. Guo, you did meet with Mr. Major 8 and Mr. Kim to prepare for your deposition 9 today, correct? 10 MR. VARTAN: Objection. 11 MR. KIM: Objection. Asked and 12 answered. 13 A. Fifth Amendment. 14 Q. Ms. Guo, are you represented by 15 Mr. Kim and Mr. Major? 16 MR. VARTAN: Objection. 17 MR. KIM: Objection to form. Asked 18 and answered. 19 A. Fifth Amendment. 20 Q. Okay. 21 Ms. Guo, you are the sole member of 22 Hudson Diamond Holdings, correct? 23 A. (In English) On the advise of my 24 lawyer, I respectfully decline to answer on the 25 basis of the Fifth Amendment which protects IN RE: HO WAN KWOK, ET AL., 23

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2 innocent people from the need to answer 3 questions if the truth might be used to help 4 create a misleading impression that they were 5 somehow involved in a crime that they did not 6 commit. Thank you. 7 Q.

8 that you just read? 9 MR. VARTAN: Objection.

10 have to answer. 11 MR. LUFT:

12 Mr. Vartan. 13 Of course she does. 14 MR. TWARDY:

15 on this. 16 MR. LUFT:

17 privilege, but then instruct her not to 18 answer, and then we will go from there. 19 But you can't tell her she just doesn't 20 have to answer the question.

23 MR. TWARDY:

24 question you asked about Hudson, and she 25 answered that.

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1 M. GUO 2 And she's not going to answer 3 questions about -- about what she discusses 4 with her lawyer. 5 MR. LUFT: Guys, stop. If you want 6 to instruct her not to answer, do so. 7 MR. VARTAN: I just did. 8 BY MR. LUFT: 9 Q. Ms. Guo, let's have a clear record. 10 Who wrote the statement that you 11 just read into the record? 12 MR. VARTAN: We're instructing her 13 not to answer. 14 MR. TWARDY: I'm instructing her not 15 to answer. 16 BY MR. LUFT: 17 Q. Ms. Guo, are you going to follow 18 your counsel's advice? 19 A. Correct, yes. 20 Q. Okay. 21 Ms. Guo, Hudson Diamond Holdings is 22 a hundred percent owner of Hudson Diamond New 23 York, correct? 24 THE INTERPRETER: Would like to 25 reinterpret. IN RE: HO WAN KWOK, ET AL., 25

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1 M. GUO 2 A. Fifth Amendment. 3 Q. Okay. 4 Ms. Guo, your father installed you 5 as the nominal sole member of Hudson Diamond 6 Holdings, correct? 7 A. Fifth Amendment, Fifth Amendment. 8 Q. Okay. Let's mark as Exhibit 1 9 document bearing the Bates stamp of HR 0003095. 10 (Guo Exhibit 1, Document Entitled: 11 Hudson Diamond Holdings LLC with Bates 12 Stamp of HR 0003095, marked for 13 identification.) 14 MR. TWARDY: We don't see it yet. 15 MR. LUFT: It's in the chat. 16 MR. KIM: Is it Tab 2? 17 MR. LUFT: Yes. 18 THE WITNESS: Tab 2. Oh, okay. 19 MR. TWARDY: Okay. We have it now. 20 Thank you. 21 MR. LUFT: Great. 22 BY MR. LUFT: 23 Q. Ms. Guo, this is a document 24 entitled: Hudson Diamond Holdings LLC, and 25 under member it has the name of the member and IN RE: HO WAN KWOK, ET AL., 26

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1 M. GUO 2 it lists your name at 162 East 64th Street, New 3 York, New York 10065 -- 4 (Multiple speakers.) 5 A. Is this a question? Can you please 6 repeat your question? 7 Q. Yes, ma'am. I'm asking, if you see 8 what I've just pointed out to you on the 9 document? 10 A. Yes, I can see this document. 11 Q. And the information contained in it 12 is accurate, correct? 13 A. Fifth Amendment. 14 Q. Okay. 15 Let's mark as Exhibit 2 a document 16 bearing the Bates stamp HR 0002584 titled 17 Hudson Diamond New York LLC. 18 (Guo Exhibit 2, Document Entitled: 19 Hudson Diamond New York LLC with Bates 20 Stamp of HR 0002584, marked for 21 identification.) 22 MR. TWARDY: This is Tab 3? 23 MR. LUFT: Correct, sir. 24 MR. TWARDY: Thank you. 25 It would help if you would let us IN RE: HO WAN KWOK, ET AL., 27

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2 know the tabs in addition to the document 3 numbers, please, just to expedite this. 4 Thank you. 5 MR. LUFT:

6 this. 7 MR. TWARDY:

8 it promptly. 9 MR. LUFT: Okay.

10 documents so far. This is the second. 11 MR. VARTAN:

12 that because they are labeled in the chat, 13 Tab 2, Tab 3. 14 MR. LUFT: I get that.

15 my point was simply that there is -- that's 16 not on the document.

17 code.

19 MR. VARTAN:

23 MR. LUFT: That is fine.

24 help try to label that. 25 MR. TWARDY: Thank you, Avi.

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1 M. GUO 2 MR. LUFT: Not a problem. 3 BY MR. LUFT: 4 Q. Ms. Guo, do you have what has been 5 marked as Exhibit 2 in front of you now? 6 A. I see it. 7 Q. Do you see this document says: 8 Hudson Diamond New York LLC and its address is 9 also 162 East 64th Street, New York, New York 10 10065, and under the member name it says Hudson 11 Diamond Holdings LLC, and under membership 12 interest 100 percent with officers of Yvette 13 Wang and Max Krasner. 14 Do you see that? 15 A. Yes, I see it. 16 Q. And the information contained in 17 this document is accurate as well, correct? 18 A. Fifth Amendment. 19 MR. LUFT: Let's mark as Exhibit 3 20 the document bearing the Bates stamp HR 21 002382 through 88, and for attorney 22 reference that will show up as Tab 4. 23 (Guo Exhibit 3, October 25, 2019, 24 Letter to Yvette Wang with Bates Stamp of 25 HR 002382 through 88, marked for IN RE: HO WAN KWOK, ET AL., 29

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1 M. GUO 2 identification.) 3 MR. TWARDY: Thank you. 4 BY MR. LUFT: 5 Q. Let me know when you've had the 6 chance to see the document. Please let me 7 know. 8 (Document review.) 9 MR. TWARDY: We're in the process of 10 reviewing it, Avi. 11 MR. LUFT: I understand. There's no 12 rush. 13 (Document review.) 14 BY MR. LUFT: 15 Q. My first question is just going to 16 be about the first page of the document and 17 then I'll ask some inside. And we will share 18 our screen so that you guys can see what I'm 19 looking at. 20 MR. TWARDY: Thank you. 21 MR. LUFT: No problem. I've lost 22 video for Austin. Is he still here? 23 MR. KIM: Yeah, I'm still here. I'm 24 still here. Now you can see me. 25 MR. LUFT: Oh, okay. Just wanted to IN RE: HO WAN KWOK, ET AL., 30

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2 make sure we didn't lose anything. 3 MR. KIM:

5 document, but I do note that I just want to 6 on the record reserve our right to object 7 to the extent that the document discloses

9 Greenwich Land LLC and the defendant, whose 10 name is Hing Chi Ngok in the complaint.

12 questions. 13 MR. LUFT:

14 any privileged relationship between Hodgson 15 Russ and your client? 16 MR. KIM:

17 record to the extent that the document here 18 discloses privileged information that 19 belongs to the defendant, I'm objecting. 20 But I'm not instructing the witness not to 21 answer, nor am I saying this document you 22 can't ask questions about.

23 that's all I'm doing. 24 MR. LUFT: Okay.

25 it's proper if you don't have a good faith

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1 M. GUO 2 basis to believe there is a privileged 3 relationship, to tell a witness, hey, maybe 4 you shouldn't answer stuff because there 5 might be privileged stuff -- 6 (Multiple speakers.) 7 MR. KIM: I didn't instruct the 8 witness to do anything, Avi. I didn't 9 instruct the witness to do anything. 10 MR. LUFT: Okay. I get it. You're 11 just throwing it out there that, you know, 12 maybe there's privileged stuff in here and 13 maybe you should be worried about it. 14 Again, you -- it's not proper. We 15 will move on. But you cannot suggest to 16 the witness that there's a privileged 17 relationship if you don't have a good faith 18 basis to -- 19 (Multiple speakers.) 20 MR. KIM: I'm making no suggestion 21 of a privilege relationship to the witness. 22 You can ask your questions to the 23 witness. 24 MR. LUFT: Okay. 25 BY MR. LUFT: IN RE: HO WAN KWOK, ET AL., 32

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1 M. GUO 2 Q. Ms. Guo, do you see that the 3 person -- it says to a Ms. Yvette Wang at 4 Golden Spring New York LTD? 5 A. I see it. 6 Q. Ms. Wang worked at Golden Spring, 7 correct? 8 A. Fifth Amendment. 9 Q. The person Ms. Wang reported to at 10 Golden Spring was your father, the debtor, 11 correct? 12 A. Fifth Amendment. 13 Q. Okay. 14 It says: I attach for your review a 15 draft organizational chart for the various 16 entities for which we -- meaning Hodgson 17 Russ -- have custody of the corporate records. 18 Do you see that? 19 A. I see it. 20 Q. And the entities for which they 21 attach corporate charts, China Golden Spring 22 Group Hong Kong Limited; Genever Holdings 23 Corporation, Greenwich Land LLC, Hudson Diamond 24 Holdings, Hudson Diamond New York, and Hudson 25 Diamond Inc., as well as Saraca Media Group, IN RE: HO WAN KWOK, ET AL., 33

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2 are all entities controlled and owned by your 3 father, the debtor, correct? 4 MR. KIM: Objection to form.

6 before, so I want to make sure my objection 7 to form has been placed on the record. 8 A. Fifth Amendment. 9 Q.

11 organizational chart for the Hudson Diamond 12 Holdings LLC, Hudson Diamond New York LLC. 13 Do you see that? 14 A. I see it. 15 Q.

16 are the -- you control Hudson Diamond Holdings 17 LLC, which directly controls Hudson Diamond New 18 York LLC, correct? 19 MR. KIM: Objection. 20 MR. VARTAN: Objection. 21 A. Fifth Amendment. 22 Q.

23 nominal name controlling Hudson Diamond 24 Holdings LLC, in fact, it is your father, the 25 debtor, that controlled Hudson Diamond Holdings

2 LLC as well as Hudson Diamond New York LLC, 3 correct? 4 MR. VARTAN: Objection. 5 MR. KIM: Objection to form. 6 Foundation.

7 you are holding here.

9 Avi, the defendants in this case for which 10 this deposition was noticed are Greenwich 11 Land LLC and Hing Chi Ngok.

12 that you are delving into other matters

14 proceeding for which this deposition is 15 being held, I think that it's improper.

17 be focused on the issues relevant to the 18 defendants in this action. 19 MR. TWARDY:

20 THE INTERPRETER:

21 interpreting the question. Should I? 22 MR. LUFT:

23 question.

24 hear Mr. Austin's speech, you are welcome 25 to translate that as well.

1 M. GUO 2 it's relevant, but she's welcome to hear 3 everything said. 4 THE INTERPRETER: Okay. Can the 5 interpreter clarify. The interpreter will 6 have to interpret the question, and I will 7 give a summarize of the discussion. How is 8 that? 9 MR. LUFT: That's fine. I just want 10 to be clear that: Ms. Guo, here is my 11 question, and then I get a answer -- clear 12 answer to the question. 13 THE INTERPRETER: Yes, to allow the 14 interpreter to interpret the question. 15 MR. TWARDY: We don't need to debate 16 interpreted. 17 THE INTERPRETER: Okay. Thank you, 18 sir. The interpreter will interpret the 19 question. 20 MR. TWARDY: Thank you. 21 A. Fifth Amendment. 22 Q. And if we would look at the page 23 before, there is a similar organizational chart 24 for -- this time for Greenwich Land. 25 And this one says -- lists your IN RE: HO WAN KWOK, ET AL.,

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2 mother, Hing Chi Ngok -- or let me just lay a 3 basic foundation.

5 mother, correct? 6 A.

7 Ngok. 8 Q.

9 correct? 10 A. Correct. 11 Q.

12 Guo, correct? 13 A. Fifth Amendment. 14 Q.

15 your father as Miles Kwok? 16 A. Fifth Amendment. 17 Q.

18 would you prefer me to him as -- let me just 19 strike that.

21 and the debtor, you will know who I'm referring 22 to? 23 A. Yes. 24 Q. Okay. We will do it that way. 25 Okay.

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1 M. GUO 2 it show -- it lists Ms. Ngok as controlling 3 Greenwich Land LLC. 4 Do you see that? 5 MR. KIM: Objection to form. 6 Mischaracterizes the document. Foundation. 7 MR. VARTAN: Objection. 8 A. I see it. 9 Q. Ms. Guo, in fact, at all times your 10 father has owned and controlled Greenwich Land 11 LLC, correct? 12 MR. KIM: Objection to form. 13 MR. VARTAN: Objection. 14 MR. KIM: Foundation. 15 A. Fifth Amendment. 16 Q. Turn back to Hudson Diamond 17 Holdings. At all times your father has owned 18 Hudson Diamond Holdings, correct? 19 MR. KIM: Objection to form. 20 MR. VARTAN: Objection. 21 A. Fifth Amendment. 22 Q. At all times your father has 23 controlled Hudson Diamond Holdings? 24 MR. VARTAN: Objection. 25 MR. KIM: Objection to form.

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2 A. Fifth Amendment. 3 Q.

4 all of the assets of Hudson Diamond Holdings? 5 MR. VARTAN: Objection. 6 MR. KIM: Objection to form. 7 BY MR. LUFT: 8 Q. Correct? 9 MR. KIM: Objection to form.

10 and answered -- (audio interruption) -- 11 notice in this deposition in this adversary 12 proceeding. 13 MR. LUFT: Sorry. What's that?

14 didn't hear you, Austin. You cut out. 15 MR. KIM: I apologize.

16 objecting to the form of the question.

17 Hudson Diamond is not a defendant in this

19 deposition has been noticed. 20 MR. LUFT: That is true.

21 not a defendant.

22 question, but it is a true fact that they 23 are not a defendant. 24 You can go ahead. 25 THE INTERPRETER:

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1 M. GUO 2 interpreter to interpret the question. 3 A. Fifth Amendment. 4 Q. At all times your father has 5 controlled all of the assets of Hudson Diamond 6 Holdings, correct? 7 MR. VARTAN: Objection. 8 MR. KIM: Objection to form. 9 A. Pith amendment. 10 Q. At all times any transfers of money 11 of Hudson Diamond Holdings and any of its 12 affiliates and subsidiaries have been at the 13 direction of your father, the debtor, correct? 14 MR. VARTAN: Objection. 15 MR. KIM: Objection to form. 16 A. Fifth Amendment. 17 Q. At all times your father has owned 18 Hudson Diamond New York LLC, correct? 19 MR. VARTAN: Objection. 20 MR. KIM: Objection to form. 21 A. Fifth Amendment. 22 Q. At all times your father has 23 controlled Hudson Diamond New York LLC, 24 correct? 25 MR. KIM: Objection to form. IN RE: HO WAN KWOK, ET AL., 40

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1 M. GUO 2 MR. VARTAN: Objection. 3 A. Fifth Amendment. 4 Q. At all times your father has owned 5 and controlled all assets of Hudson Diamond New 6 York LLC, correct? 7 MR. KIM: Objection to form. 8 MR. VARTAN: Objection. 9 A. Fifth Amendment. 10 Q. At all times any transfers of money 11 to and from Hudson Diamond New York LLC has 12 been done at the sole direction and control of 13 your father, correct? 14 MR. VARTAN: Objection. 15 MR. KIM: Objection to form. 16 Foundation. 17 A. Fifth Amendment. 18 Q. All bank accounts of Hudson Diamond 19 Holdings were opened at the direction of your 20 father, the debtor, correct? 21 MR. VARTAN: Objection. 22 MR. KIM: Objection to form. 23 A. Fifth Amendment. 24 Q. At all times your father, the 25 debtor, has exclusive control of all bank IN RE: HO WAN KWOK, ET AL., 41

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2 accounts in the name of Hudson Diamond 3 Holdings, correct? 4 MR. VARTAN: Objection. 5 MR. KIM: Objection to form. 6 A. Fifth Amendment. 7 MR. KIM:

8 for about an hour.

9 good time for you to break or if you want 10 to finish your line. 11 MR. LUFT:

12 of questioning. 13 MR. KIM: Okay. 14 MR. LUFT: Thanks. 15 BY MR. LUFT: 16 Q.

17 New York LLC were opened at the direction of 18 your father, the debtor, correct? 19 MR. VARTAN: Objection. 20 MR. KIM: Objection to form. 21 A. Fifth Amendment. 22 Q.

23 Hudson Diamond New York LLC have been 24 exclusively controlled by your father, the 25 debtor, correct?

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2 MR. VARTAN: Objection. 3 MR. KIM: Objection to form.

5 earlier.

6 in this proceeding.

7 going on for, I guess, about 10, 15 minutes 8 on questions of a nondefendant entity. 9 Avi, if you want to put some foundation for 10 this, then I can better understand.

11 it stands, it looks like you are asking 12 about a nonparty for some other reason 13 that's not related to this litigation. 14 MR. LUFT:

15 polite and just say that if you have been 16 reading the transcripts of this -- of the 17 depositions in this case, it would be 18 abundantly clear why all these questions 19 are directly relevant.

20 to say any more, okay?

22 answer my question. 23 THE INTERPRETER:

24 interpreter to interpret. 25 A. Fifth Amendment.

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2 Q.

3 have ever been in the bank accounts of Hudson 4 Diamond New York LLC are funds that were owned 5 and controlled by your father, the debtor, 6 correct? 7 MR. KIM: Objection to form. 8 MR. VARTAN: Objection. 9 MR. KIM: Foundation. Vague. 10 A. Fifth Amendment. 11 Q.

12 bank accounts at your father's directions at 13 Capital One Bank, correct? 14 MR. VARTAN: Objection. 15 MR. KIM: Objection to form. 16 Foundation. Vague. 17 A. Fifth Amendment. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 46 of 142

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2 record, but I don't -- look, Austin, if you

6 MR. KIM:

7 transcript so I can't stipulate to anything 8 right now that I haven't seen.

9 just -- I'm just thinking to streamline 10 this, if it is public -- if it's part of 11 the public record already, then I tend to 12 agree with Lee that we can streamline this 13 just to save time on the record, but this 14 is your deposition so you can proceed how 15 you wish. 16 MR. LUFT:

17 this.

18 but if you -- like I said, if you guys want 19 to read the transcript, and you want to 20 stipulate, make an agreement so that it's 21 clear that that transcript is admissible, 22 you know, we can take this up -- or that I 23 can use it as testimony, we can try to do 24 that, but the fact is I think at this point 25 I'll just be faster to go -- just to go

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1 M. GUO 2 through this now. 3 So let's just keep moving. 4 THE INTERPRETER: Counsel, do you 5 need -- 6 MR. LUFT: No, I don't -- 7 MR. TWARDY: You don't need to -- 8 Echo, you don't need to interpret that. 9 THE INTERPRETER: Okay. Counsels, 10 can we establish lengthy discussion will 11 not be interpreted? 12 MR. LUFT: I think we should 13 probably do it on a case-by-case basis. 14 I'm not worried. It's fine with me. But 15 it's up to her counsel what they want to do 16 on that. 17 THE INTERPRETER: Okay. Okay. 18 MR. TWARDY: If we need you, we will 19 let you know, Echo. Thank you. 20 THE INTERPRETER: Thank you. So 21 please proceed.

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13 MR. LUFT:

14 fine time for a break if you'd like one. 15 MR. KIM: Sounds great. 16 MR. TWARDY: Five minutes. 17 MR. KIM:

18 it's the first one? I don't care. 19 MR. TWARDY:

20 more me. 21 MR. KIM: Okay. Great. 22 MR. TWARDY: Thank you.

24 MR. LUFT: Okay.

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2 MR. KIM: Okay. Great.

3 just want to -- before you go down this 4 line of questioning, and this actually

6 exhibits as well.

7 documents that were not produced in this 8 litigation, and these are not documents

10 defendants.

11 we're seeing this document, as well as the 12 other documents as well.

15 introduced in this adversary proceeding for 16 the first time at a deposition as opposed 17 to be being produced in response to the 18 defendant's document requests.

19 that basis, I do object to questioning the 20 witness on documents that have not been 21 produced in this litigation.

22 this document that's Tab 8 -- I don't know 23 which exhibit number it is, but it's the 24 Capital One account for Hudson Diamond for 25 the period July 1, 2019, and July 31, 2019,

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2 with a Bates number of Cap Kwok 000049 and

4 introduced as well. 5 THE INTERPRETER:

6 need his statement being translated? 7 MR. LUFT: I don't feel a need.

10 MR. TWARDY:

11 translated. 12 Sorry.

13 blitz. 14 THE INTERPRETER: Thank you. 15 MR. LUFT: Are we ready to proceed? 16 MR. TWARDY: We're ready. 17 BY MR. LUFT: 18 Q. Okay.

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4 withhold responsive material documents from 5 the defendants in this proceeding.

6 this is a topic that we have previously met 7 and conferred about.

8 improper to have -- for the trustee to 9 examine the witness on brand-new documents 10 that have, to date, been concealed from 11 production.

13 goes for this document, the prior documents 14 that were not produced in this litigation, 15 and any other additional documents going 16 forward.

18 can have a standing objection to the extent 19 that these are documents that are being 20 used at this deposition that have not been 21 previously produced to the defendants.

23 Avi?

24 objection to these documents or do you want 25 to me to raise it every time? Up to you.

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2 MR. LUFT:

3 objection. Okay.

4 one second?

5 one second.

7 THE INTERPRETER:

8 interpreter hasn't interpreted the question 9 yet. Do you need that to be interpreted? 10 MR. LUFT:

11 you on? 12 MR. KIM: Yes. 13 MR. LUFT: Are we on the record? 14 THE COURT REPORTER: Yes, we are. 15 MR. LUFT:

16 was produced to you.

17 documents have been produced to you.

18 were all produced to you on September 5th.

20 MR. LUFT:

21 two days ago, handed to your colleague as 22 an exhibit, also at the deposition of 23 Ms. Ngok.

25 confirm that?

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1 M. GUO 2 withdraw your objection? 3 MR. KIM: Sorry about that. I was 4 on mute. I get it. You are right; I'm 5 wrong. Let's go. 6 MR. LUFT: Go where? To you 7 withdrawing your objections? 8 MR. KIM: I just said you're right; 9 I'm wrong. You got it, yes. To this 10 particular document, yes. 11 MR. LUFT: As to the ones before it 12 that you made -- 13 (Multiple speakers.) 14 MR. KIM. -- I have to confirm, but 15 if you represent that they were produced, 16 okay, but then I have to confirm it. 17 MR. LUFT: These documents were 18 produced to you, Mr. Kim, and I think next 19 time before you level an accusation you 20 should check. Let's move on. 21 BY MR. LUFT: 22 Q. Okay. 23 Ms. Guo, let's mark as exhibit -- Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 61 of 142

4 MR. LUFT:

5 I'm spending no more time with you.

7 MR. KIM: Excuse me.

8 representing that they have been produced

9 I'll take your representation.

10 looking at the recent production that was 11 made the other day and I'm not seeing the 12 opening documents.

13 representing they were produced, then maybe 14 they were.

15 objection.

16 have the objection. 17 MR. LUFT: We will check.

18 that at least one of them is also -- been 19 already an exhibit in the record in this 20 case -- in the -- in the main case.

21 will move on.

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2 Q.

3 has never been a director, officer, or member 4 of Hudson Diamond New York, correct? 5 A. Fifth Amendment. 6 Q.

7 had no ability to force Hudson Diamond New York 8 to transfer money to Greenwich Land LLC, 9 correct? 10 MR. KIM: Objection to form. 11 Foundation. Vague. 12 A. Fifth Amendment.

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12 MR. LUFT:

13 hold on one second. Sorry. 14 MR. TWARDY:

15 second, please.

17 MR. TWARDY: Okay. 18 BY MR. LUFT: 19 Q.

21 MR. VARTAN:

22 room. 23 MR. LUFT: Oh, sorry.

24 we went off the record. 25 MR. TWARDY: Sorry. Thank you.

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1 M. GUO 2 MR. VARTAN: He's back. 3 MR. LUFT: Do people want a break? 4 I'm okay with one, one way or the other. 5 MR. VARTAN: I leave it up to Mei. 6 MR. TWARDY: Mei is fine. 7 MR. LUFT: Okay. How is the court 8 reporter? 9 THE COURT REPORTER: I'm okay for 10 another twenty minutes, and then a break. 11 MR. LUFT: Okay. I'll keep it in 12 mind. And please remind me, Lisa, if I 13 forget, okay? 14 MR. TWARDY: Maybe we will get done. 15 MR. LUFT: That would be nice. 16 BY MR. LUFT: 17 Q. Okay. 18 Let's -- 19 MR. LUFT: Are we back on the 20 record? 21 THE COURT REPORTER: Yes. 22 MR. TWARDY: Please. 23 BY MR. LUFT: 24 Q. Ms. Guo, are you familiar with an 25 entity called Gypsy Mei Food Services LLC? IN RE: HO WAN KWOK, ET AL., 79

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2 A. Fifth Amendment. 3 Q.

4 the sole member of, correct? 5 MR. KIM: Objection to form. 6 A. Fifth Amendment. 7 MR. LUFT:

8 the document bearing the Bates stamped HR 9 0003000 through 3032.

12 Services LLC., marked for identification.) 13 MR. LUFT:

14 was produced to us by Hodgson Russ as the 15 file for Gypsy Mei Food Services LLC. 16 MR. TWARDY: Tab 28? 17 MR. LUFT: Correct.

19 A. Okay. I see it. 20 Q. Okay.

22 direct you to pages HR 0000 -- sorry -- 23 00003019 through 24, which is titled -- 24 MR. KIM:

25 used at Ms. Guo's deposition?

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1 M. GUO 2 MR. LUFT: It was, Austin. It was 3 marked as an exhibit. 4 MR. KIM: Okay. All right. 5 MR. LUFT: As I was saying, this is 6 titled: Limited liability company 7 agreement of Gypsy Mei Food Services LLC. 8 Q. Do you see that? 9 A. I see it. 10 MR. KIM: And just to clarify our 11 prior objection, I understand that this 12 document was introduced as an exhibit 13 before, but we still reserve our objection 14 to the document being introduced by the 15 trustee at depositions for the first time. 16 I'm not sure if this -- I'm not familiar if 17 this document has been produced in document 18 production. 19 It appears that it's been introduced 20 as exhibits to deposition proceedings. So 21 reserve our objection. But go ahead, Avi. 22 MR. LUFT: Okay. 23 BY MR. LUFT: 24 Q. We turn to the page ending at 3023. 25 You see it says: In witness whereof, the sole IN RE: HO WAN KWOK, ET AL., 81

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2 member has executed this agreement to be 3 effective as the ay near first above written.

5 signature line is Mei Guo? 6 A. I see it. 7 Q. And that's your signature, correct? 8 A. Fifth Amendment. 9 Q. Okay.

11 Schedule A, it says:

14 \$100 and membership interest 100 percent? 15 A. I see it. 16 Q.

17 correct and accurate, correct? 18 A. Fifth Amendment.

Q.

20 originally created with the idea that you would 21 be opening some type of drinking establishment, 22 correct? 23 MR. VARTAN: Objection. 24 MR. KIM: Objection to form. 25 A. Fifth Amendment. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 84 of 142

2 Q.

3 think it was intended to be a bar on the Lower 4 East Side, correct? 5 MR. VARTAN: Objection. 6 MR. KIM: Objection to form. 7 THE INTERPRETER:

8 second. 9 A. Fifth Amendment. 10 Q.

11 LLC never actually operated any businesses, 12 correct? 13 MR. VARTAN: Objection. 14 MR. KIM: Objection to form. 15 A. Fifth Amendment. 16 Q.

17 any money to any other entities, correct? 18 MR. KIM: Objection to form. 19 MR. VARTAN: Objection. 20 A. Fifth Amendment. 21 Q.

22 any revenue, correct? 23 MR. VARTAN: Objection. 24 MR. KIM: Objection to form. 25 A. Fifth Amendment.

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2 Q.

3 bank account, though, correct? 4 MR. KIM: Objection to form. 5 A. Fifth Amendment. 6 Q.

7 Sterling National Bank, correct? 8 MR. KIM: Objection to form. 9 A. Fifth Amendment. 10 Q.

11 Mei Food Services bank account were funds that 12 were transferred at the direction of your 13 father, the debtor, correct? 14 MR. KIM: Objection to form. 15 A. Fifth Amendment. 16 Q.

17 transferred into Gypsy Mei Food Service's bank 18 account, those funds always remained under the 19 control and ownership of your father, the 20 debtor, correct? 21 MR. VARTAN: Objection. 22 MR. KIM: Objection to form. 23 A. Fifth Amendment. 24 Q.

25 remained under the ownership and control of

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2 your father, the debtor, Gypsy Mei Food Service 3 has never held any other funds, correct? 4 MR. VARTAN: Objection. 5 MR. KIM: Objection to form. 6 A. Fifth Amendment. 7 Q.

8 funds into a bank account held by Gypsy Mei 9 Food Services is strictly for the purpose of 10 helping your father hide his assets from his 11 creditors, correct? 12 MR. VARTAN: Objection. 13 MR. KIM: Objection to form. 14 A. Fifth Amendment. 15 MR. LUFT:

16 break around now. Why don't we do so.

18 BY MR. LUFT: 19 Q. Good afternoon, Ms. Guo.

20 you? 21 A. I'm very good. Thank you. 22 Q.

23 question coming from Exhibit 12 that we looked 24 at right before the break.

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3 Is that still your address? 4 A. Fifth Amendment. 5 Q. Sorry.

6 attorney just handed you? 7 MR. TWARDY: It's the microphone. 8 MR. LUFT: I just can't see, guys. 9 It's not -- I'm not accusing anyone of 10 anything.

11 right. 12 MR. TWARDY:

13 yeah. The other one was on the blink. 14 MR. LUFT: What? 15 MR. TWARDY:

16 blink. It wasn't working. 17 MR. LUFT: There's no problem, guys. 18 I was just curious what it was.

19 accusing anyone of anything. 20 A. Okay. 21 Q. Okay.

? 24 A. Fifth Amendment. 25 Q.

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2 by your father, the debtor? 3 MR. KIM: Objection to form. 4 MR. VARTAN: Objection. 5 A. Fifth Amendment. 6 Q. Okay.

8 Ms. Guo.

14 MR. KIM: One second, I'm sorry. 15 Could the reporter just read back, I guess, 16 Avi's introduction? I just wanted to make 17 sure I heard that correctly. 18 (Question was read back as follows:

19 "QUESTION: Ms. Guo, to speed this 20 process along a little bit I'll represent 21 to you that the house at the 33 Ferncliff 22 Road in Greenwich, Connecticut, that was 23 held in the name of Greenwich Land, was 24 sold in April 2022, okay?") 25 MR. KIM: I'm going to object to Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 89 of 142

2 your characterization.

3 question so I'm not going to object to 4 the -- as a question, but I'm just going to 5 object to the characterization.

6 can go ahead.

11 MR. KIM:

12 it seems to me you are characterizing it 13 as -- I don't know what you mean by held in 14 the name of Greenwich Land LLC.

15 MR. LUFT: That's fine. 16 MR. KIM:

17 owned or I don't know what the -- what 18 words you want to use. 19 MR. LUFT: I'll tell you what.

20 just leave those words out.

21 important to me.

23 MR. KIM: Excuse me. 24 MR. LUFT:

25 words out then. Okay.

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1 M. GUO 2 is the date and the sale so that Mei has a 3 clear understanding. 4 MR. KIM: Well -- 5 MR. TWARDY: Just so I'm clear -- 6 okay. 7 MR. LUFT: I'm going to withdraw the 8 prior statement and I'll say it again 9 hopefully in a way that everyone agrees 10 with. 11 BY MR. LUFT: 12 Q. Ms. Guo, I will represent to you 13 that the house at 33 Ferncliff Road -- let me 14 strike that.

3 A. Understood.

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24 Q.

25 correct?

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2 A. Fifth Amendment. 3 Q.

4 sworn declaration to this court stating that 5 you've tried to call Mr. Krasner, correct? 6 A. Fifth Amendment. 7 Q.

8 Mr. Krasner was one of the people who handled 9 the business and affairs of Hudson Diamond 10 Holdings, correct? 11 MR. KIM: Objection to form. 12 A. Fifth Amendment. 13 Q.

14 with Mr. Krasner's signature, correct? 15 MR. VARTAN: Objection. 16 MR. KIM: Objection to form. 17 A. Fifth Amendment. 18 Q.

19 Mr. Krasner's signature numerous times, 20 correct? 21 MR. KIM: Objection to form. 22 MR. VARTAN: Objection. 23 A. Fifth Amendment.

24 Q.

25 director of Greenwich Land LLC, correct?

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2 A. Fifth Amendment. 3 Q.

4 officer of Greenwich Land LLC, correct? 5 A. Fifth Amendment. 6 Q.

7 of Greenwich Land LLC, correct? 8 A. Fifth Amendment. 9 Q.

10 ownership in Greenwich Land LLC, correct? 11 A. Fifth Amendment.

2 MR. VARTAN: Objection.

12 MR. TWARDY:

13 us. 14 MR. VARTAN: It's Melissa. 15 MR. LUFT: It's Lee's colleague. 16 Okay. 17 BY MR. LUFT: 18 Q.

19 Food Services on all of these checks is spelled 20 M-E-I, correct? 21 A. Correct. 22 Q.

23 first name, correct? 24 A. Correct. 25 Q.

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2 named after you, correct? 3 MR. VARTAN: Objection. 4 MR. KIM: Objection to form. 5 A. Fifth Amendment. 6 Q. Okay.

14 MR. VARTAN: Objection. 15 MR. KIM: Objection to form. 16 One second here.

17 objection.

18 to finish. 19 MR. LUFT:

20 answer. 21 THE INTERPRETER:

22 interpreting. 23 MR. KIM: I understand.

24 like the court reporter to repeat the 25 question.

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1 M. GUO 2 standing, but I just want to make sure I 3 understood what the exact words of the 4 question were. 5 MR. LUFT: We need the witnesses 6 answer and then you can do whatever -- you 7 can repeat whatever you want. 8 MR. KIM: I don't want to repeat. 9 I'd like the court reporter to read back 10 the question. 11 MR. LUFT: No, guys. Please let the 12 interpreter just give us her answer. She 13 answered. I need to hear what it is. 14 MR. KIM: Okay. 15 THE INTERPRETER: The interpreter 16 needs to interpret the objection, but I 17 didn't hear the answer. The objection 18 is -- 19 MR. LUFT: We don't need the 20 objection. We just need -- the objection 21 was after the question and answer. 22 MR. TWARDY: Yes. 23 MR. LUFT: We just repeat the 24 question. 25 MR. TWARDY: Repeat the answer. IN RE: HO WAN KWOK, ET AL., 106

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3 Q. Okay. 4 MR. LUFT:

5 what you want. 6 MR. KIM:

7 to repeat the question that was asked to 8 make sure I understood what was asked. 9 (Question was read back as follows:

17 MR. KIM: Yeah, objection to form. 18 MR. VARTAN: Same. 19 MR. LUFT: Okay.

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4 Q. Okay.

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2 connection with your father's bankruptcy by the 3 law firm of Zeisler & Zeisler, correct? 4 A. Correct. 5 Q.

6 your father in connection with his bankruptcy, 7 correct? 8 A. Fifth Amendment.

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25 MR. LUFT:

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25 MR. LUFT: Okay.

wasn't to a question.

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17 MR. LUFT:

minute. I might be finishing up.

18 want to check some stuff, okay?

20 BY MR. LUFT: 21 Q.

22 for you at this time.

23 your time today. I appreciate it. 24 THE WITNESS:

25 you. Thank you. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 134 of 142

1 M. GUO 2 MR. TWARDY: Have a good day, everybody. 4 MR. LUFT: Mr. Kim, do you have any questions? 6 MR. KIM: No questions for the defendants. I just want to, you know, mark this deposition transcript confidential, if that's agreeable to the trustee. 10 MR. LUFT: It's not. I don't have a problem with designating the portions that are confidential, but I think the idea of marking the entire thing confidential is problematic and will create issues with the Court in terms of sealing the courtroom and 16 whatnot. 17 So if you guys want to look at the transcript and go back and note if there is something in here that you think is confidential, I don't have a problem with that, but I don't think we should designate the entire transcript confidential. 23 MR. KIM: Okay. Then for purposes of today, we can agree that once the final transcript is provided, the parties can IN RE: HO WAN KWOK, ET AL., 133

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2 designate or propose designating portions

4 confidential. 5 Is that agreeable? 6 MR. LUFT: Sure. 7 MR. KIM: Okay. 8 MR. TWARDY: Might I ask a question?

10 bankruptcy court and how it acts.

11 about this -- the deposition of the video 12 aspects of this?

13 or is this just we're doing this via Zoom 14 and none of the video will be disclosed to 15 anybody? 16 MR. LUFT:

17 deposition was recorded. 18 Right, Lisa? 19 THE COURT REPORTER: That's correct. 20 This isn't videoed today. 21 MR. TWARDY: Okay.

22 much. I just wanted to clarify that.

24 weigh in on the transcript if we think that

800.211.DEPO (3376) EsquireSolutions.com 03:02

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2 confidential? 3 MR. LUFT:

4 do that?

5 Austin?

7 confidential and then we can talk about it. 8 I don't -- you know, that's okay with me. 9 You tell me.

10 want to use is okay with me. 11 MR. TWARDY:

12 Austin -- I guess, I'll work it through 13 Austin, would make the most sense.

14 and I disagree, I will be coming to you. 15 MR. LUFT: That's okay.

17 mean to exclude you.

18 too.

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1 M. GUO 2 MS. WERNICK: That's fine. 3 MR. KIM: So we will figure all this 4 out once the final is issued. 5 MR. LUFT: Perfect. 6 MR. TWARDY: Thank you, all, 7 everybody. 8 (Time Noted: 3:04 p.m.) 9 10 11 --------------------- 12 MEI GUO 13 14 Subscribed and sworn to before me 15 this day of 2023. 16 17 --------------------------------------- 18 19 20 21 22 23 24 25 800.211.DEPO (3376)

1 2 C E R T I F I C A T E 3 4 STATE OF NEW YORK ) 5 ) ss.: 6 COUNTY OF NEW YORK ) 7 I, LISA M. MURACO, a Notary Public 8 within and for the State of New York, 9 Florida, Massachusetts, do hereby certify: 10 That MEI GUO, the witness whose 11 deposition is hereinbefore set forth, was 12 duly sworn by me and that such deposition 13 is a true record of the testimony given by 14 such witness. 15 I further certify that I am not 16 related to any of the parties to this 17 action by blood or marriage; and that I am 18 in no way interested in the outcome of this 19 matter. 20 IN WITNESS WHEREOF, I have hereunto 21 set my hand this 13th day of September, 22 2023. 23 ------------------------- 24 LISA M. MURACO 25 800.211.DEPO (3376)

2 I N D E X WITNESS PAGE MEI GUO MR. LUFT 7 8 E X H I B I T S DESCRIPTION PAGE Guo Exhibit 1, Document Entitled: 26 Hudson Diamond Holdings LLC with Bates Stamp of HR 0003095 Guo Exhibit 2, Document Entitled: 27 Hudson Diamond New York LLC with Bates Stamp of HR 0002584 Guo Exhibit 3, October 25, 2019, Letter 29 to Yvette Wang with Bates Stamp of HR 002382 through 88 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 140 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 141 of 142

5 Services LLC.

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ERRATA SHEET FOR THE TRANSCRIPT OF:

Case Name: KWOK v GREENWICH, et al. Dep. Date:

Deponent:

CORRECTIONS:

THIS____DAY OF____________, 2023.

(Notary Public) MY COMMISSION EXPIRES:_______