--- type: court_doc id: "court_ctb_2292_36" court: "CTB" case_no: "22-50073" doc_number: 2292 doc_type: "EXHIBIT" filed_date: "2023-10-26" lang: "en" machine_translated: false url: "https://mubeitech.com/en/court/court_ctb_2292_36" json_url: "https://mubeitech.com/api/court/court_ctb_2292_36" --- # Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #2292-36 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) EsquireSolutions.com September 13, 2023 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 MEI GUO IN RE: HO WAN KWOK, ET AL., Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 5 of 142 September 13, 2023 800.211.DEPO (3376) EsquireSolutions.com 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 September 13, 2023 EsquireSolutions.com 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 September 13, 2023 YVer1f MEI GUO IN RE: HO WAN KWOK, ET AL., 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. 20　- oOo - September 13, 2023 10:17 10:18 10:18 10:18 YVer1f EsquireSolutions.com 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 September 13, 2023 10:19 10:19 10:20 10:20 10:21 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 10 of 142 September 13, 2023 10:21 10:21 10:22 10:22 10:23 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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? · September 13, 2023 10:23 10:29 10:30 10:30 10:30 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 12 of 142 September 13, 2023 10:30 10:31 10:31 10:31 10:32 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 13 of 142 September 13, 2023 10:33 10:33 10:33 10:34 10:34 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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. · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 14 of 142 September 13, 2023 10:34 10:34 10:35 10:35 10:35 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 15 of 142 September 13, 2023 10:36 10:36 10:36 10:36 10:36 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 16 of 142 MEI GUO September 13, 2023 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 800.211.DEPO (3376) EsquireSolutions.com 10:36 10:36 10:37 10:37 10:37 YVer1f Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 17 of 142 September 13, 2023 10:37 10:37 10:37 10:38 10:38 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 18 of 142 September 13, 2023 10:39 10:39 10:40 10:40 10:40 YVer1f EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 19 of 142 September 13, 2023 10:40 10:41 10:41 10:41 10:42 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 20 of 142 MEI GUO September 13, 2023 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 800.211.DEPO (3376) EsquireSolutions.com 10:42 10:42 10:42 10:42 10:42 YVer1f Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 21 of 142 September 13, 2023 10:42 10:42 10:43 10:43 10:43 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · MEI GUO IN RE: HO WAN KWOK, ET AL., Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 22 of 142 September 13, 2023 10:43 10:43 10:43 10:44 10:44 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 23 of 142 September 13, 2023 10:44 10:44 10:44 10:44 10:45 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 24 of 142 September 13, 2023 10:45 10:45 10:46 10:46 10:47 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 25 of 142 MEI GUO September 13, 2023 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. 800.211.DEPO (3376) EsquireSolutions.com 10:47 10:47 10:47 10:47 10:47 YVer1f Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 26 of 142 September 13, 2023 10:48 10:48 10:48 10:48 10:49 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 27 of 142 September 13, 2023 10:49 10:50 10:50 10:50 10:51 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 28 of 142 September 13, 2023 10:51 10:52 10:52 10:52 10:53 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 29 of 142 September 13, 2023 10:53 10:53 10:53 10:53 10:53 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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. · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 30 of 142 September 13, 2023 10:54 10:54 10:54 10:55 10:55 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 31 of 142 September 13, 2023 10:56 10:56 10:57 10:57 10:57 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 32 of 142 MEI GUO September 13, 2023 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 800.211.DEPO (3376) EsquireSolutions.com 10:57 10:58 10:58 10:58 10:58 YVer1f Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 33 of 142 September 13, 2023 10:58 10:58 10:59 10:59 10:59 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 34 of 142 September 13, 2023 10:59 11:00 11:00 11:01 11:01 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 35 of 142 September 13, 2023 11:02 11:02 11:03 11:03 11:03 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · September 13, 2023 11:03 11:03 11:04 11:04 11:04 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · September 13, 2023 11:05 11:05 11:05 11:05 11:06 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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., · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 38 of 142 September 13, 2023 11:06 11:07 11:07 11:08 11:08 YVer1f EsquireSolutions.com 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, Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 39 of 142 September 13, 2023 11:08 11:09 11:09 11:09 11:10 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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. · MEI GUO IN RE: HO WAN KWOK, ET AL., Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 40 of 142 September 13, 2023 11:10 11:10 11:11 11:11 11:11 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 41 of 142 September 13, 2023 11:11 11:12 11:12 11:13 11:13 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 42 of 142 September 13, 2023 11:13 11:14 11:14 11:14 11:15 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 43 of 142 September 13, 2023 11:15 11:16 11:16 11:16 11:16 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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? · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 44 of 142 MEI GUO September 13, 2023 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. 800.211.DEPO (3376) EsquireSolutions.com 11:16 11:17 11:17 11:17 11:17 YVer1f Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 45 of 142 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. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 46 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 47 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 48 of 142 MEI GUO September 13, 2023 IN RE: HO WAN KWOK, ET AL., 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 800.211.DEPO (3376) EsquireSolutions.com 11:23 11:23 11:24 11:24 11:24 YVer1f Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 49 of 142 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. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 50 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 51 of 142 1　M. GUO 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. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 54 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 55 of 142 MEI GUO September 13, 2023 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, 800.211.DEPO (3376) EsquireSolutions.com 11:43 11:43 11:43 11:44 11:44 YVer1f Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 56 of 142 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. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 57 of 142 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. 800.211.DEPO (3376) EsquireSolutions.com 11:47 11:47 11:47 11:47 11:47 YVer1f Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 59 of 142 September 13, 2023 11:48 11:48 11:49 11:49 11:49 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · MEI GUO IN RE: HO WAN KWOK, ET AL., Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 60 of 142 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 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. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 62 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 63 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 64 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 65 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 66 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 67 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 69 of 142 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. 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 70 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 72 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 73 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 74 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 76 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 77 of 142 1　M. GUO 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 79 of 142 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. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 80 of 142 September 13, 2023 12:31 12:32 12:32 12:32 12:32 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 81 of 142 September 13, 2023 12:32 12:33 12:33 12:34 12:34 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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? · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 82 of 142 September 13, 2023 12:35 12:35 12:36 12:36 12:36 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 83 of 142 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. 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. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 84 of 142 September 13, 2023 12:39 12:39 12:40 12:40 12:40 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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. · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 85 of 142 September 13, 2023 12:41 12:41 12:42 12:42 12:43 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 86 of 142 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 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 87 of 142 1　M. GUO 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 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 88 of 142 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 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 89 of 142 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 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 90 of 142 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. 1　M. GUO 3　A. Understood. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 92 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 93 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 94 of 142 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 95 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 97 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 98 of 142 1　M. GUO 1　M. GUO 24　Q. Ms. Guo, you know Max Krasner, 25　correct? Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 101 of 142 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. 1　M. GUO 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? Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 104 of 142 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. 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 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 107 of 142 September 13, 2023 02:03 02:03 02:03 02:03 02:03 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 108 of 142 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　Doc 2292-36　Filed 10/26/23 of 142　Entered 10/26/23 20:46:12　Page 109 1　M. GUO 4　Q.　Okay. 25　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. 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 113 of 142 1　M. GUO 1　M. GUO 25　MR. LUFT: Why don't we go off the Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 116 of 142 1　M. GUO 1　M. GUO 1　M. GUO 1　M. GUO 1　M. GUO 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 123 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 124 of 142 1　M. GUO 25　MR. LUFT: Okay. I assume that wasn't to a question. She -- she is saying Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 125 of 142 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 127 of 142 1　M. GUO 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 128 of 142 1　M. GUO 1　M. GUO Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 131 of 142 1　M. GUO 1　M. GUO Case 22-50073　Doc 2292-36　Filed 10/26/23　Entered 10/26/23 20:46:12　Page 133 of 142 1　M. GUO 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. Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 134 of 142 September 13, 2023 03:01 03:02 03:02 03:02 03:02 YVer1f 800.211.DEPO (3376) EsquireSolutions.com 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 · 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 800.211.DEPO (3376) EsquireSolutions.com 03:02 03:03 03:03 03:03 03:03 YVer1f Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 136 of 142 September 13, 2023 03:03 03:03 03:04 03:04 YVer1f EsquireSolutions.com 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.) 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) EsquireSolutions.com 03:04 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) EsquireSolutions.com 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 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 Company Agreement of Gypsy Mei Food 5　Services LLC. 15　QUESTIONS INSTRUCTED NOT TO ANSWER 16　Page Line 17　18 Case 22-50073 Doc 2292-36 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 142 of 142 September 13, 2023 EsquireSolutions.com 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:_______ MEI GUO IN RE: HO WAN KWOK, ET AL.,