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

METADATA

Defendant: Guo Wengui / Miles Guo / Ho Wan Kwok
Court: CTB
Case No.: 22-50073
ECF #: 2292
Type: EXHIBIT
Filed: 2023-10-26

FULL TEXT

### **Exhibit 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

800.211.DEPO (3376) EsquireSolutions.com

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)

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800.211.DEPO (3376) EsquireSolutions.com

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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MEI GUO

IN RE: HO WAN KWOK, ET AL.,

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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

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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)

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IN RE: HO WAN KWOK, ET AL.,

| 1 | | |----|--------------------------------------------| | 2 | IT IS HEREBY STIPULATED AND AGREED | | 3 | by and between the attorneys for the | | 4 | respective parties herein, that filing and | | 5 | sealing be and the same are hereby waived. | | 6 | IT IS FURTHER STIPULATED AND AGREED | | 7 | that all objections, except as to the form | | 8 | of the question, shall be reserved to the | | 9 | time of the trial. | | 10 | IT IS FURTHER STIPULATED AND AGREED | | 11 | that the within deposition may be sworn to | | 12 | and signed before any officer authorized | | 13 | to administer an oath, with the same | | 14 | force and effect as if signed and sworn | | 15 | to before the Court. | | 16 | | | 17 | | | 18 | | | 19 | | | 20 | - oOo - | | 21 | | | 22 | | | 23 | | | 24 | | | 25 | | | | | | | |

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MEI GUO

IN RE: HO WAN KWOK, ET AL.,

| 1 | M. GUO | |----|--------------------------------------------------| | 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. | | 5 | M E I G U O, called as a witness, having been | | 6 | duly sworn by a Notary Public, was examined and | | 7 | testified through the interpreter as follows: | | 8 | MR. LUFT: Thank you. Do we have to | | 9 | do appearances or do we have them on the | | 10 | record already? | | 11 | THE COURT REPORTER: I have them on | | 12 | the record already, but if counsel wants to | | 13 | do them, it's fine. | | 14 | MR. LUFT: That's fine with me. | | 15 | EXAMINATION BY | | 16 | MR. LUFT: | | 17 | Q. Good morning, Ms. Guo. How are you? | | 18 | A. I am quite good. Thank you. | | 19 | Q. Good. Ms. Guo, I've deposed you | | 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. Ms. Guo, your counsel has informed | | 25 | the counsel for the parties in this case prior | | | | | | |

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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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| 1 | M. GUO | |----|-------------------------------------------------| | 2 | A. I understand. | | 3 | Q. Ms. Guo, if for any reason you don't | | 4 | understand one of my questions, will you let me | | 5 | know? | | 6 | A. I will. | | 7 | Q. And if you -- do we have an | | 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. Ms. Guo, did you do anything to | | 14 | prepare for your deposition today? | | 15 | A. Fifth Amendment. | | 16 | Q. I forgot to ask you one more basic | | 17 | question. | | 18 | Ms. Guo, is there any reason you can | | 19 | not offer truthful testimony today? | | 20 | A. No. | | 21 | Q. Did you review any documents to | | 22 | prepare for your deposition today? | | 23 | A. Fifth Amendment. | | 24 | Q. Ms. Guo, who is representing you | | 25 | here today? | | | |

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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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| 1 | M. GUO | |----|-------------------------------------------------| | 2 | A. Fifth Amendment. | | 3 | Q. Please tell me everything you've | | 4 | spoken to Mr. Kim about prior to today? | | 5 | MR. KIM: I'm going to object here | | 6 | for just one second here. Object to the | | 7 | form and also instruct the witness to the | | 8 | extent that she was acting in the capacity | | 9 | to interpret, then I would advise the | | 10 | witness not to answer, based on the | | 11 | privilege of the defendants, but the | | 12 | witness is free to raise her own objection | | 13 | as well. | | 14 | MR. VARTAN: And I'm going to join | | 15 | in the objection. | | 16 | A. The answer is Fifth Amendment. | | 17 | MR. LUFT: Mr. Kim, I just want to | | 18 | understand your objection. | | 19 | Has Ms. Guo served as an interpreter | | 20 | at meetings you've been at before? | | 21 | MR. KIM: I'm not being deposed | | 22 | today. My objection is clear. It's on the | | 23 | record, and the witness has raised her own | | 24 | objection as well. So I think that's -- | | 25 | MR. LUFT: No, Austin, come on. | | | |

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| 1 | M. GUO | |----|----------------------------------------------| | 2 | That's not reasonable. You made an | | 3 | objection based on the idea that she may | | 4 | have been a translator. This is the first | | 5 | I've ever heard of that. And that's okay. | | 6 | But I would like to understand. You tell | | 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. But you just sit | | 10 | there and make objections and say, But I | | 11 | won't tell you what's that about. I don't | | 12 | think you can do that. | | 13 | MR. KIM: Okay. We raised our | | 14 | objection. It's on the record. It's | | 15 | pretty clear what the basis of the | | 16 | objection is, and we are going to stand by | | 17 | it. | | 18 | MR. LUFT: It's a hundred percent | | 19 | not clear. You raised an objection to the | | 20 | extent she's been a translator, but she's | | 21 | not testified that she's ever been a | | 22 | translator. You won't tell me if she's | | 23 | ever been a translator, so I don't | | 24 | understand how you can give an instruction | | 25 | not to answer based on being a translator | | | |

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| 1 | M. GUO | |----|-----------------------------------------------| | 2 | if there's no foundation that she's ever | | 3 | been a translator or who she's been a | | 4 | translator for. | | 5 | MR. KIM: You can ask -- | | 6 | (Multiple speakers.) | | 7 | MR. LUFT: -- just understand the | | 8 | parameters. I'm not asking for what she | | 9 | said or anything else. I understand how a | | 10 | translator works with privilege. But you | | 11 | have to at least establish that she's been | | 12 | a translator. | | 13 | You want to tell me she's been the | | 14 | translator for a meeting, that's fine. But | | 15 | to just throw it out there as if -- and | | 16 | give an instruction not to answer, I don't | | 17 | think is proper. So I'm just trying to | | 18 | understand, Austin, what's going on. | | 19 | MR. KIM: That's fine. And so you | | 20 | can ask the deponent who is sitting here to | | 21 | be -- to answer your questions, and so -- | | 22 | MR. LUFT: Austin -- | | 23 | (Multiple speakers.) | | 24 | MR. KIM: -- Ms. Guo is here. You | | 25 | can ask her the question. We've raised our |

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| 1 | M. GUO | |----|-------------------------------------------------| | 2 | objection. We stand by it. I think it's a | | 3 | proper objection. If you disagree, that's | | 4 | fine. You don't have to agree with me, but | | 5 | that's our objection, and I'm not here to | | 6 | answer questions. | | 7 | (Multiple speakers.) | | 8 | MR. LUFT: No, but you do have | | 9 | duties of candor and to have a good faith | | 10 | basis upon which to object. The purpose of | | 11 | form objections is to allow the other | | 12 | attorney to understand an issue so that we | | 13 | can have a clear record. And to just | | 14 | basically say I'm not going to tell you | | 15 | anything about why I'm saying it, | | 16 | especially when the witness is taking the | | 17 | Fifth onto these questions, I think is | | 18 | unreasonable. I think it's improper, and I | | 19 | certainly don't understand it, because if | | 20 | she's been the translator, then I'll | | 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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| 1 | M. GUO | |----|----------------------------------------------| | 2 | idea that you don't have to say anything, | | 3 | you can just give instructions not to | | 4 | answer to a witness who's not yours, | | 5 | that -- | | 6 | (Multiple speakers.) | | 7 | MR. KIM: That's a | | 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. I'm not going to get | | 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. Then we | | 19 | will do it your way, Austin. | | 20 | BY MR. LUFT: | | 21 | Q. Ms. Guo, how often has Mr. Kim given | | 22 | you answers to be stated at this deposition? | | 23 | MR. VARTAN: Objection. | | 24 | A. Fifth Amendment. | | 25 | Q. Did Mr. Austin -- have you met with | | | |

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| 1 | M. GUO | |----|------------------------------------------------| | 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. Did Mr. Kim and Mr. Major tell you | | 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. | | 14 | Have you served as an interpreter at | | 15 | meetings with -- that Mr. Kim and Mr. Major | | 16 | have been at? | | 17 | MR. VARTAN: Objection. | | 18 | MR. KIM: Objection to form. Asked | | 19 | and answered. | | 20 | A. Fifth Amendment. | | 21 | Q. Did Mr. Major and Mr. Kim tell you | | 22 | that certain answers would be more helpful to | | 23 | your mom's case? | | 24 | MR. VARTAN: Objection to form. | | 25 | MR. KIM: Objection. Asked and | | | | | | |

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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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| 1 | M. GUO | |----|-----------------------------------------------| | 2 | MR. KIM: I said before, we stated | | 3 | our objection pretty clearly. Now, I mean | | 4 | you are not satisfied with it, which is | | 5 | fine. | | 6 | MR. LUFT: No, no, no. She's not | | 7 | your client so I need to know -- | | 8 | (Multiple speakers.) | | 9 | MR. KIM: -- it's a valid objection. | | 10 | We've raised it on the record. | | 11 | MR. LUFT: She's not your client, so | | 12 | what privilege are you invoking about a | | 13 | conversation between you and her? | | 14 | MR. KIM: Again, as I said before at | | 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. I think you're well | | 19 | aware of that. We've invoked the privilege | | 20 | several times now -- | | 21 | MR. LUFT: I'm not aware of any | | 22 | interpretation privilege. | | 23 | (Multiple speakers.) | | 24 | MR. LUFT: Austin, there have been | | 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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| 1 | M. GUO | |----|-----------------------------------------------| | 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. Ms. Guo, who wrote that statement | | 8 | that you just read? | | 9 | MR. VARTAN: Objection. You don't | | 10 | have to answer. | | 11 | MR. LUFT: Of course, she does, | | 12 | Mr. Vartan. | | 13 | Of course she does. | | 14 | MR. TWARDY: I'll assert a privilege | | 15 | on this. | | 16 | MR. LUFT: You won't insert the | | 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. Give an | | 21 | instruction -- | | 22 | (Multiple speakers.) | | 23 | MR. TWARDY: She answered the | | 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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| 1 | M. GUO | |----|---------------------------------------------| | 2 | know the tabs in addition to the document | | 3 | numbers, please, just to expedite this. | | 4 | Thank you. | | 5 | MR. LUFT: Tabs have no bearing on | | 6 | this. | | 7 | MR. TWARDY: Just for us to get to | | 8 | it promptly. | | 9 | MR. LUFT: Okay. There's been two | | 10 | documents so far. This is the second. | | 11 | MR. VARTAN: Avi, he's only saying | | 12 | that because they are labeled in the chat, | | 13 | Tab 2, Tab 3. | | 14 | MR. LUFT: I get that. There are -- | | 15 | my point was simply that there is -- that's | | 16 | not on the document. It's in an internal | | 17 | code. | | 18 | (Multiple speakers.) | | 19 | MR. VARTAN: -- but it's how it's | | 20 | coming up in terms of how you name | | 21 | things -- | | 22 | (Multiple speakers.) | | 23 | MR. LUFT: That is fine. I will | | 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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| 1 | M. GUO | |----|---------------------------------------------| | 2 | make sure we didn't lose anything. | | 3 | MR. KIM: And on this document, I | | 4 | don't have an objection to the full | | 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 | | 8 | any privileged information related to | | 9 | Greenwich Land LLC and the defendant, whose | | 10 | name is Hing Chi Ngok in the complaint. | | 11 | But you can go ahead and ask your | | 12 | questions. | | 13 | MR. LUFT: Austin, are you aware of | | 14 | any privileged relationship between Hodgson | | 15 | Russ and your client? | | 16 | MR. KIM: I'm just putting on the | | 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. That's -- | | 23 | that's all I'm doing. | | 24 | MR. LUFT: Okay. I don't believe | | 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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| 1 | M. GUO | |----|-------------------------------------------------| | 2 | are all entities controlled and owned by your | | 3 | father, the debtor, correct? | | 4 | MR. KIM: Objection to form. | | 5 | I wasn't sure if I was on mute | | 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. If you turn a couple pages in to | | 10 | page 5 of the document, there's an | | 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. And this document reflects that you | | 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. Ms. Guo, while you are listed as the | | 23 | nominal name controlling Hudson Diamond | | 24 | Holdings LLC, in fact, it is your father, the | | 25 | debtor, that controlled Hudson Diamond Holdings |

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| 1 | M. GUO | |----|----------------------------------------------| | 2 | LLC as well as Hudson Diamond New York LLC, | | 3 | correct? | | 4 | MR. VARTAN: Objection. | | 5 | MR. KIM: Objection to form. | | 6 | Foundation. Mischaracterizes the document | | 7 | you are holding here. | | 8 | And then just as a matter of scope | | 9 | Avi, the defendants in this case for which | | 10 | this deposition was noticed are Greenwich | | 11 | Land LLC and Hing Chi Ngok. To the extent | | 12 | that you are delving into other matters | | 13 | that are outside of the adversary | | 14 | proceeding for which this deposition is | | 15 | being held, I think that it's improper. | | 16 | I would suggest that the deposition | | 17 | be focused on the issues relevant to the | | 18 | defendants in this action. | | 19 | MR. TWARDY: You don't need to -- | | 20 | THE INTERPRETER: The interpreter is | | 21 | interpreting the question. Should I? | | 22 | MR. LUFT: You should interpret my | | 23 | question. If Ms. Guo would like her to | | 24 | hear Mr. Austin's speech, you are welcome | | 25 | to translate that as well. I don't think | | | |

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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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MEI GUO

| 1 | M. GUO | |----|-------------------------------------------------| | 2 | mother, Hing Chi Ngok -- or let me just lay a | | 3 | basic foundation. | | 4 | Hing Chi Ngok is the name of your | | 5 | mother, correct? | | 6 | A. Yes, my mother's name is Hing Chi | | 7 | Ngok. | | 8 | Q. Your father's name is Ho Wan Kwok, | | 9 | correct? | | 10 | A. Correct. | | 11 | Q. He also goes by Miles Kwok and Miles | | 12 | Guo, correct? | | 13 | A. Fifth Amendment. | | 14 | Q. Have you ever heard anyone refer to | | 15 | your father as Miles Kwok? | | 16 | A. Fifth Amendment. | | 17 | Q. For purposes of today's deposition, | | 18 | would you prefer me to him as -- let me just | | 19 | strike that. | | 20 | Today when I refer to your father | | 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. So if we look at this page, | | | | | | |

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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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MEI GUO

IN RE: HO WAN KWOK, ET AL.,

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| 1 | M. GUO | |----|-----------------------------------------------| | 2 | A. Fifth Amendment. | | 3 | Q. At all times your father has owned | | 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. Asked | | 10 | and answered -- (audio interruption) -- | | 11 | notice in this deposition in this adversary | | 12 | proceeding. | | 13 | MR. LUFT: Sorry. What's that? I | | 14 | didn't hear you, Austin. You cut out. | | 15 | MR. KIM: I apologize. I'm | | 16 | objecting to the form of the question. And | | 17 | Hudson Diamond is not a defendant in this | | 18 | adversary proceeding for which the | | 19 | deposition has been noticed. | | 20 | MR. LUFT: That is true. They are | | 21 | not a defendant. It's not relevant to my | | 22 | question, but it is a true fact that they | | 23 | are not a defendant. | | 24 | You can go ahead. | | 25 | THE INTERPRETER: Allow the | | | |

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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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| 1 | M. GUO | |----|-----------------------------------------------| | 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: Hey, Avi, we've been going | | 8 | for about an hour. Up to you, if this is a | | 9 | good time for you to break or if you want | | 10 | to finish your line. | | 11 | MR. LUFT: I want to finish my line | | 12 | of questioning. | | 13 | MR. KIM: Okay. | | 14 | MR. LUFT: Thanks. | | 15 | BY MR. LUFT: | | 16 | Q. All bank accounts of Hudson Diamond | | 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. At all times all bank accounts of | | 23 | Hudson Diamond New York LLC have been | | 24 | exclusively controlled by your father, the | | 25 | debtor, correct? | | | |

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| 1 | M. GUO | |----|-----------------------------------------------| | 2 | MR. VARTAN: Objection. | | 3 | MR. KIM: Objection to form. And | | 4 | just I want to repeat what I've said | | 5 | earlier. Hudson Diamond isn't a defendant | | 6 | in this proceeding. And this has been | | 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. But as | | 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: Austin, I'm going to be | | 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. And I'm not going | | 20 | to say any more, okay? | | 21 | And I would like the witness to | | 22 | answer my question. | | 23 | THE INTERPRETER: Allow the | | 24 | interpreter to interpret. | | 25 | A. Fifth Amendment. | | | |

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| 1 | M. GUO | |----|------------------------------------------------| | 2 | Q. Ms. Guo, all funds in the bank that | | 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. Hudson Diamond New York LLC opened | | 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. | | 18 | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |----|---------------------------------------------| | 2 | record, but I don't -- look, Austin, if you | | 3 | want to stipulate that the -- that | | 4 | Ms. Guo's testimony -- | | 5 | (Multiple speakers.) | | 6 | MR. KIM: I haven't seen the | | 7 | transcript so I can't stipulate to anything | | 8 | right now that I haven't seen. But I'm | | 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: I think we need to do | | 17 | this. I don't think that's how it works, | | 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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| 1 | M. GUO | |----|------------------------------------------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 13 | MR. LUFT: Mr. Kim, this would be a | | 14 | fine time for a break if you'd like one. | | 15 | MR. KIM: Sounds great. | | 16 | MR. TWARDY: Five minutes. | | 17 | MR. KIM: Want ten minutes since | | 18 | it's the first one? I don't care. | | 19 | MR. TWARDY: Five minutes is fine | | 20 | more me. | | 21 | MR. KIM: Okay. Great. | | 22 | MR. TWARDY: Thank you. | | 23 | (Recess is taken.) | | 24 | MR. LUFT: Okay. |

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| 1 | M. GUO | |---|--------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |----|-----------------------------------------------| | 2 | MR. KIM: Okay. Great. Yeah, I | | 3 | just want to -- before you go down this | | 4 | line of questioning, and this actually | | 5 | applies in -- to the prior couple of | | 6 | exhibits as well. These appear to be | | 7 | documents that were not produced in this | | 8 | litigation, and these are not documents | | 9 | that were provided to counsel for the | | 10 | defendants. So this is the first time that | | 11 | we're seeing this document, as well as the | | 12 | other documents as well. | | 13 | I would just like to, you know, | | 14 | inquire why the documents are being | | 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. And so on | | 19 | that basis, I do object to questioning the | | 20 | witness on documents that have not been | | 21 | produced in this litigation. It applies to | | 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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| 1 | M. GUO | |----|--------------------------------------------| | 2 | with a Bates number of Cap Kwok 000049 and | | 3 | the prior documents that have been | | 4 | introduced as well. | | 5 | THE INTERPRETER: Counsels, do you | | 6 | need his statement being translated? | | 7 | MR. LUFT: I don't feel a need. | | 8 | It's up -- | | 9 | (Multiple speakers.) | | 10 | MR. TWARDY: We don't need that | | 11 | translated. | | 12 | Sorry. Our microphone is on the | | 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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### Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 58 of 142 MEI GUO September 13, 2023

| 1 | M. GUO | |----|---------------------------------------------| | 2 | can take this up later as to why the | | 3 | trustee has deemed it appropriate to | | 4 | withhold responsive material documents from | | 5 | the defendants in this proceeding. And | | 6 | this is a topic that we have previously met | | 7 | and conferred about. And I think it's | | 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. | | 12 | And that's a standing objection that | | 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. | | 17 | I can state the same objection or we | | 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. | | 22 | How would you like to handle it, | | 23 | Avi? Do you want to have a standing | | 24 | objection to these documents or do you want | | 25 | to me to raise it every time? Up to you. | | | |

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| 1 | M. GUO | |----|------------------------------------------------| | 2 | MR. LUFT: Mr. Kim, I heard your | | 3 | objection. Okay. Can we just hold on for | | 4 | one second? Let's go off the record for | | 5 | one second. | | 6 | (Recess is taken.) | | 7 | THE INTERPRETER: Counsel, the | | 8 | interpreter hasn't interpreted the question | | 9 | yet. Do you need that to be interpreted? | | 10 | MR. LUFT: No, is -- Mr. Kim, are | | 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: Mr. Kim, this document | | 16 | was produced to you. All of these | | 17 | documents have been produced to you. They | | 18 | were all produced to you on September 5th. | | 19 | (Audio interruption.) | | 20 | MR. LUFT: This document was used | | 21 | two days ago, handed to your colleague as | | 22 | an exhibit, also at the deposition of | | 23 | Ms. Ngok. | | 24 | Do you want to take a minute and | | 25 | confirm that? And then would you like to | | | |

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MEI GUO

IN RE: HO WAN KWOK, ET AL.,

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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 --

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| 1 | M. GUO | |----|---------------------------------------------| | | | | 4 | MR. LUFT: We're moving -- Mr. Kim, | | 5 | I'm spending no more time with you. | | 6 | (Multiple speakers.) | | 7 | MR. KIM: Excuse me. If you are | | 8 | representing that they have been produced | | | | | 9 | I'll take your representation. I'm just | | 10 | looking at the recent production that was | | 11 | made the other day and I'm not seeing the | | 12 | opening documents. But if you are | | 13 | representing they were produced, then maybe | | 14 | they were. And if they were, then no | | 15 | objection. And if they weren't, then I | | 16 | have the objection. | | 17 | MR. LUFT: We will check. I do know | | 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. We | | 21 | will move on. | | | | | | | | | |

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| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |----|-------------------------------------------------| | 2 | Q. Ms. Guo, your mother, Hing Chi Ngok, | | 3 | has never been a director, officer, or member | | 4 | of Hudson Diamond New York, correct? | | 5 | A. Fifth Amendment. | | 6 | Q. Ms. Guo, your mother, Hing Chi Ngok, | | 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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| 1 | M. GUO | |----|------------------------------------------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | 12 | MR. LUFT: Let's mark as exhibit -- | | 13 | hold on one second. Sorry. | | 14 | MR. TWARDY: Bear with me one | | 15 | second, please. | | 16 | (Pause in the proceedings.) | | 17 | MR. TWARDY: Okay. | | 18 | BY MR. LUFT: | | 19 | Q. Are you familiar with an entity | | 20 | named -- | | 21 | MR. VARTAN: Avi, Stan is out of the | | 22 | room. | | 23 | MR. LUFT: Oh, sorry. I didn't know | | 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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| 1 | M. GUO | |----|--------------------------------------------| | 2 | A. Fifth Amendment. | | 3 | Q. In fact, it's an entity that you are | | 4 | the sole member of, correct? | | 5 | MR. KIM: Objection to form. | | 6 | A. Fifth Amendment. | | 7 | MR. LUFT: Let's mark as Exhibit 12 | | 8 | the document bearing the Bates stamped HR | | 9 | 0003000 through 3032. | | 10 | (Guo Exhibit 12, Limited Liability | | 11 | Company Agreement of Gypsy Mei Food | | 12 | Services LLC., marked for identification.) | | 13 | MR. LUFT: I'll represent to you it | | 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. | | 18 | (Document review.) | | 19 | A. Okay. I see it. | | 20 | Q. Okay. | | 21 | And, specifically, I'm going to | | 22 | direct you to pages HR 0000 -- sorry -- | | 23 | 00003019 through 24, which is titled -- | | 24 | MR. KIM: Real quick, Avi, was this | | 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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| 1 | M. GUO | |----|--------------------------------------------------| | 2 | member has executed this agreement to be | | 3 | effective as the ay near first above written. | | 4 | And then the name underneath the | | 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. | | 10 | Do you see on the next page under | | 11 | Schedule A, it says: Member name and address, | | 12 | Mei Guo, | | | , capital contribution | | 14 | \$100 and membership interest 100 percent? | | 15 | A. I see it. | | 16 | Q. And all of that information is | | 17 | correct and accurate, correct? | | 18 | A. Fifth Amendment. | | 19 | | | | Q. And Gypsy Mei Food Services LLC was | | 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. |

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| 1 | M. GUO | |----|------------------------------------------------| | 2 | Q. And I can't recall exactly, but I | | 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: Just give me a | | 8 | second. | | 9 | A. Fifth Amendment. | | 10 | Q. In fact, but Gypsy Mei Food Services | | 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. Gypsy Mei Food Services never loaned | | 17 | any money to any other entities, correct? | | 18 | MR. KIM: Objection to form. | | 19 | MR. VARTAN: Objection. | | 20 | A. Fifth Amendment. | | 21 | Q. Gypsy Mei Food Services never earned | | 22 | any revenue, correct? | | 23 | MR. VARTAN: Objection. | | 24 | MR. KIM: Objection to form. | | 25 | A. Fifth Amendment. | | | |

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| 1 | M. GUO | |----|------------------------------------------------| | 2 | Q. Gypsy Mei Food Service did have a | | 3 | bank account, though, correct? | | 4 | MR. KIM: Objection to form. | | 5 | A. Fifth Amendment. | | 6 | Q. It had a bank account at the | | 7 | Sterling National Bank, correct? | | 8 | MR. KIM: Objection to form. | | 9 | A. Fifth Amendment. | | 10 | Q. Any funds ever deposited in a Gypsy | | 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. And despite any funds being | | 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. Other than funds that always | | 25 | remained under the ownership and control of | | | |

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| 1 | M. GUO | |----|-------------------------------------------------| | 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. The sole purpose of any transfer of | | 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: I said we would take a | | 16 | break around now. Why don't we do so. | | 17 | (Recess is taken.) | | 18 | BY MR. LUFT: | | 19 | Q. Good afternoon, Ms. Guo. How are | | 20 | you? | | 21 | A. I'm very good. Thank you. | | 22 | Q. Ms. Guo, I just want to ask you one | | 23 | question coming from Exhibit 12 that we looked | | 24 | at right before the break. It lists your | | 25 | address as | | | |

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| 1 | M. GUO | |----|---------------------------------------------| | 2 | | | 3 | Is that still your address? | | 4 | A. Fifth Amendment. | | 5 | Q. Sorry. What is the device your | | 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. Oh, I see it's a microphone, | | 11 | right. | | 12 | MR. TWARDY: It's a microphone, | | 13 | yeah. The other one was on the blink. | | 14 | MR. LUFT: What? | | 15 | MR. TWARDY: The other was on the | | 16 | blink. It wasn't working. | | 17 | MR. LUFT: There's no problem, guys. | | 18 | I was just curious what it was. It's not | | 19 | accusing anyone of anything. | | 20 | A. Okay. | | 21 | Q. Okay. | | 22 | Was it -- have you ever been lived | | 23 | at ? | | 24 | A. Fifth Amendment. | | 25 | Q. Is that that is owned | | | | | | |

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| 1 | M. GUO | |---|----------------------------------| | 2 | by your father, the debtor? | | 3 | MR. KIM: Objection to form. | | 4 | MR. VARTAN: Objection. | | 5 | A. Fifth Amendment. | | 6 | Q. Okay. | | 7 | You can put that document aside, | | 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

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| 1 | M. GUO | |----|------------------------------------------------| | 2 | your characterization. It's not really a | | 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. But you | | 6 | can go ahead. | | | | | | | | | | | | | | 11 | MR. KIM: No, what I'm objecting is | | 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. I think -- | | 15 | MR. LUFT: That's fine. | | 16 | MR. KIM: -- the proper word is | | 17 | owned or I don't know what the -- what | | 18 | words you want to use. | | 19 | MR. LUFT: I'll tell you what. I'll | | 20 | just leave those words out. It's not | | 21 | important to me. The date and the sale | | 22 | is -- | | 23 | MR. KIM: Excuse me. | | 24 | MR. LUFT: I'll just leave those | | 25 | words out then. Okay. What matters to me |

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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.

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| 1 | M. GUO | | |---|-------------------|--| | 3 | A. Understood. | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |----|--------------------------------------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 24 | Q. Ms. Guo, you know Max Krasner, | | | 25 | correct? | | | | | |

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| 1 | M. GUO | | |----|-----------------------------------------------|--| | 2 | A. Fifth Amendment. | | | 3 | Q. In fact, you've previously put in a | | | 4 | sworn declaration to this court stating that | | | 5 | you've tried to call Mr. Krasner, correct? | | | 6 | A. Fifth Amendment. | | | 7 | Q. In fact, you've told the Court that | | | 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. Ms. Guo, you are extremely familiar | | | 14 | with Mr. Krasner's signature, correct? | | | 15 | MR. VARTAN: Objection. | | | 16 | MR. KIM: Objection to form. | | | 17 | A. Fifth Amendment. | | | 18 | Q. Ms. Guo, prior to today you've seen | | | 19 | Mr. Krasner's signature numerous times, | | | 20 | correct? | | | 21 | MR. KIM: Objection to form. | | | 22 | MR. VARTAN: Objection. | | | 23 | A. Fifth Amendment. | | | | | |

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| 1 | M. GUO | |---|--------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |----|------------------------------------------|--| | 2 | (Discussion held off the record.) | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 24 | Q. Ms. Guo, you've never been a | | | 25 | director of Greenwich Land LLC, correct? | | | | | |

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| 1 | M. GUO | |----|-------------------------------------------| | 2 | A. Fifth Amendment. | | 3 | Q. Ms. Guo, you have never been an | | 4 | officer of Greenwich Land LLC, correct? | | 5 | A. Fifth Amendment. | | 6 | Q. Ms. Guo, you've never been employee | | 7 | of Greenwich Land LLC, correct? | | 8 | A. Fifth Amendment. | | 9 | Q. Ms. Guo, you've never held any | | 10 | ownership in Greenwich Land LLC, correct? | | 11 | A. Fifth Amendment. | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |----|-------------------------------------------------| | 2 | MR. VARTAN: Objection. | | | | | | | | | | | | | | | | | | | | | | | | | | 12 | MR. TWARDY: May I ask who joined | | 13 | us. | | 14 | MR. VARTAN: It's Melissa. | | 15 | MR. LUFT: It's Lee's colleague. | | 16 | Okay. | | 17 | BY MR. LUFT: | | 18 | Q. Ms. Guo, the word Mei in Gypsy Mei | | 19 | Food Services on all of these checks is spelled | | 20 | M-E-I, correct? | | 21 | A. Correct. | | 22 | Q. That's the same way you spell your | | 23 | first name, correct? | | 24 | A. Correct. | | 25 | Q. And Gypsy Mei Food Services LLC was | | | |

# Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 106 of 142

| 1 | M. GUO | |----|---------------------------------------------| | 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. I have my | | 17 | objection. I'll wait for the interpreter | | 18 | to finish. | | 19 | MR. LUFT: You have to let her | | 20 | answer. | | 21 | THE INTERPRETER: I'm just | | 22 | interpreting. | | 23 | MR. KIM: I understand. I would | | 24 | like the court reporter to repeat the | | 25 | question. I have the objection still | | | |

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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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| 1 | M. GUO | |----|------------------------------------------| | | | | 3 | Q. Okay. | | 4 | MR. LUFT: Now, Austin, you can ask | | 5 | what you want. | | 6 | MR. KIM: I just wanted the reporter | | 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. | | | | | | | | | | | | | | | | | | | | | | | | |

| Case 22-50073 | |---------------| | | 1 | | 4 | | | | | | | | | | | | | | | | | 25 | | Doc 2292-36 | Filed 10/26/23 of 142 | Entered 10/26/23 20:46:12 | Page 109 | ----|-------------|--------------------------|---------------------------------|----------| | | | | | | | | | M. GUO | | | | | | | | | | Q. | Okay. | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Q. | | | Ms. Guo, you are represented in | | | | | | | |

# Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 110 of 142

| 1 | M. GUO | |---|-------------------------------------------------| | 2 | connection with your father's bankruptcy by the | | 3 | law firm of Zeisler & Zeisler, correct? | | 4 | A. Correct. | | 5 | Q. Zeisler & Zeisler also represents | | 6 | your father in connection with his bankruptcy, | | 7 | correct? | | 8 | A. Fifth Amendment. | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |---|--------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |----|--------------------------------------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 25 | MR. LUFT: Why don't we go off the | | | | | |

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| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |---|--------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |---|--------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |----------|--------------------------------------------------------------------------------------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 24 25 | MR. LUFT: Okay. I assume that wasn't to a question. She -- she is saying | | | |

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| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |---|--------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |---|--------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |---|--------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | |---|--------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

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| 1 | M. GUO | | |----------|----------------------------------------------------------------------------------------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 16 17 | MR. LUFT: Let's take a break for a minute. I might be finishing up. I just | | | 18 | want to check some stuff, okay? | | | 19 | (Recess is taken.) | | | 20 | BY MR. LUFT: | | | 21 | Q. Ms. Guo, I have no further questions | | | 22 | for you at this time. Thank you very much for | | | 23 | your time today. I appreciate it. | | | 24 | THE WITNESS: (In English) Thank | | | 25 | you. Thank you. | |

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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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### Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 135 of 142 MEI GUO September 13, 2023

IN RE: HO WAN KWOK, ET AL.,

| 1 | M. GUO | |----|-----------------------------------------------| | 2 | designate or propose designating portions | | 3 | of Ms. Guo's deposition transcript | | 4 | confidential. | | 5 | Is that agreeable? | | 6 | MR. LUFT: Sure. | | 7 | MR. KIM: Okay. | | 8 | MR. TWARDY: Might I ask a question? | | 9 | Because I'm not familiar with the | | 10 | bankruptcy court and how it acts. But what | | 11 | about this -- the deposition of the video | | 12 | aspects of this? Are they saved in any way | | 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: I don't believe today's | | 17 | deposition was recorded. | | 18 | Right, Lisa? | | 19 | THE COURT REPORTER: That's correct. | | 20 | This isn't videoed today. | | 21 | MR. TWARDY: Okay. Thank you very | | 22 | much. I just wanted to clarify that. | | 23 | And will we have an opportunity to | | 24 | weigh in on the transcript if we think that | | 25 | there is things which should be | | | |

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MEI GUO

| 1 | M. GUO | |----|-----------------------------------------------| | 2 | confidential? | | 3 | MR. LUFT: Stan, how do you want to | | 4 | do that? Do you want to do through that | | 5 | Austin? I don't have a problem with anyone | | 6 | weighing in on what they think is | | 7 | confidential and then we can talk about it. | | 8 | I don't -- you know, that's okay with me. | | 9 | You tell me. Whatever process you guys | | 10 | want to use is okay with me. | | 11 | MR. TWARDY: I'll work it through | | 12 | Austin -- I guess, I'll work it through | | 13 | Austin, would make the most sense. If he | | 14 | and I disagree, I will be coming to you. | | 15 | MR. LUFT: That's okay. | | 16 | And Melissa, I'm sorry, I didn't | | 17 | mean to exclude you. You can get involved | | 18 | too. | | 19 | (Continued on the following page to | | 20 | include jurat.) | | 21 | | | 22 | | | 23 | | | 24 | | | | | | 25 | |

### Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 137 of 142 MEI GUO September 13, 2023

IN RE: HO WAN KWOK, ET AL.,

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)

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IN RE: HO WAN KWOK, ET AL.,

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)

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137

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

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| 1 | | |----|--------------------------------------------------------------------------------| | | | | 2 | I N D E X O F E X H I B I T S(Cont'd.) | | 3 | DESCRIPTION PAGE | | 4 | Guo Exhibit 12, Limited Liability 80 Company Agreement of Gypsy Mei Food | | 5 | Services LLC. | | 6 | | | | | | 8 | | | | | | | | | | | | 12 | | | 13 | | | 14 | | | 15 | QUESTIONS INSTRUCTED NOT TO ANSWER | | 16 | Page Line | | 17 | 18 20 | | 18 | | | 19 | | | 20 | | | 21 | | | 22 | | | | | | 23 | | | 24 | | | 25 | | | | |

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| ERRATA SHEET FOR THE TRANSCRIPT OF: | | |--------------------------------------------------------------------------------------------------------------|-------------------------------| | Case Name: KWOK v GREENWICH, et al. Dep. Date: Thursday, September 13, 2023 Deponent: MEI GUO | | | | CORRECTIONS: | | Pg. Ln. | Should Read | | Now Reads | Reason | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | ___ ___ | ______________ | | ______________ | ______ | | | | | | ____________________ | | Signature of Deponent SUBSCRIBED AND SWORN BEFORE ME THIS____DAY OF____________, 2023. | | | | | | _______________________________ | | | (Notary Public) | MY COMMISSION EXPIRES:_______ |

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MEI GUO

IN RE: HO WAN KWOK, ET AL.,