Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #2292-53

Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 4 of Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 3 of 51 52

1 VIDEOGRAPHER: This is Tape No. 1 to the 1

sworn, interpreted as follows: 2 videotaped deposition of Hing Chi Ngok in the 3 HING CHI NGOK, having first been duly 3 matter of Despins, Kwok (sic) v. Greenwich 4 sworn, was deposed and testified as follows:

5 Land, et al., being heard before the United

6 Connecticut, Bridgeport Division, Case 6 DIRECT EXAMINATION 7 No. 22-50073. 7 BY MR. LUFT: 8 This deposition is being held at Meister 8 Q Good morning, Ms. Ngok. How are you? 9 Seelig & Fein on 9/11/2023 at 10:22 a.m. My 9 A Good. Thank you. 10 name is Debbie O'Toole. I'm the videographer. 10 Q Ms. Ngok, I wanted to confirm that you 11 The court reporter is Debbie Gentile. 11 understood you're appearing both as an individual 12 Counsel, will you please introduce 12 deponent today and as the corporate representative 13 yourselves and affiliations? And the witness 13 for Greenwich Land, correct? 14 will be sworn. 14 A Yes. 15 MR. LUFT: Good morning. My name is 15 MR. LUFT: And I'll ask the court reporter 16 Avi Luft. I'm with the law firm of 16 to mark as Exhibit 1 a Chapter -- a copy of the 17 Paul Hastings. I represent the Chapter 11 17 Chapter 11 trustee's notice of deposition to 18 trustee, Luc A. Despins. With me are my 18 Hing Chi Ngok. 19 colleagues, Doug Barron and Luyi Song. 19 (Exhibit 1 was marked for I.D.) 20 MR. MAJOR: Good morning. Chris Major, 20 (A discussion was held off the 21 Meister Seelig & Fein. We represent the 21 stenographic record.) 22 defendants in this adversary proceeding, 22 THE WITNESS: I am not able to read this. 23 Ms. Guo and Greenwich Land, LLC, and we're 23 BY MR. LUFT: 24 representing the witness in this deposition. 24 Q I understand. 25 MR. INTRATER: Good morning. 25 Ms. Ngok, I've handed you what is a copy

1 Zach Intrater, Brafman & Associates. I 1 of the Chapter 11's notice of deposition to Hing Chi 2 represent Ms. Guo in this deposition. 2 Ngok. Have you ever seen this document before? 3 COURT REPORTER: Usual stips? 3 MR. MAJOR: Objection to form. 4 MR. LUFT: I don't know what they are, so 4 THE WITNESS: I am not able to recognize 5 we're going to just go until we figure it out. 5 it. I cannot read English and I don't 6 MR. MAJOR:

7 understand the content of this document. BY MR. LUFT: 7 so we can get through this deposition, I'd like 8 Q Okay. 8 to have a stipulation that all objections 9 MR. LUFT: I'm going to mark as Ngok 9 except as to the form of the question are 10 Deposition Exhibit 2 a copy of the Chapter 11 10 reserved. This way we don't have to hash out 11 trustee's notice of deposition of Greenwich 11 every potential objection. 12 Land, LLC, pursuant to Federal Rule of Civil 12 MR. LUFT: That's fine. That's my 13 Procedure 30(b)(6). 13 understanding of the rules anyway. My point 14 (Exhibit 2 was marked for I.D.) 14 was not that there were none, just it's what 15 BY MR. LUFT: 15 they are. 16 Q Ms. Ngok, I've handed you what has been 16 MR. MAJOR: Okay. 17 marked as Exhibit 2, which is a copy of the notice

18 MR. LUFT:

COURT REPORTER: Please raise your 18 of deposition for Greenwich Land, LLC. Have you 19 ever seen this document before?

MR. LUFT: Sorry. 20 MR. MAJOR: Objection to form. 21 Just so it's clear for the record, this 21 THE WITNESS: I do not know what you mean. 22 deposition is of Ms. Hing Chi Ngok and of 22 INTERPRETER: Can the interpreter 23 Greenwich Land. So it's both defendants. 23 reinterpret the question? That's what Ms. Ngok 24 24 is requesting. 25 25 MR. LUFT: Okay. My only question is

1 whether she has seen this document before.

3 MR. MAJOR: Objection to form.

5 document. 6 BY MR. LUFT:

7 Q Ms. Ngok, were you provided a translation 8 of the notice of deposition by your counsel setting 9 out in Chinese what the deposition topics were for 10 today's deposition on behalf of Greenwich Land, LLC? 11 MR. MAJOR: Objection to form. Instruct 12 the witness not to answer on the grounds of 13 privilege. 13 BY MR. LUFT: 14 THE WITNESS: Okay. 14 Q Ms. Ngok, I am going to ask you a series 15 BY MR. LUFT: 15 of questions, just like I did last time. If for any 16 Q Are you going to follow your counsel's 16 reason you do not understand my question, will you 17 instruction? 17 let me know? 18 A Correct. 18 A Okay. 19 Q Ms. Ngok, are you prepared to testify on 19 Q If for -- and if -- can we have an 20 the 17 topics listed in the Greenwich Land 20 agreement that if you do not tell me that you don't 21 deposition notice? 21 understand my question, then I can assume you did 22 A Yes. 22 understand it? 23 Q Okay. You can put that aside. 23 MR. MAJOR: Objection to form. 24 Ms. Ngok, as you know, I took your 24 THE WITNESS: I don't quite understand 25 deposition on January 5, 2023, correct? 25 what you mean by that. Can you explain?

A In January, yes. I remember. 1 Page 12 BY MR. LUFT: 2 Q The rules are the same for this 2 Q Sure. If for -- if I ask you a question 3 deposition. But if you'll indulge me, I'll just go 3 and you don't tell me that you don't understand it,

4 over a couple of them, okay? 4 is it fair for me to assume that you do understand 5 A Yes, please. 5 it? 6 Q Ms. Ngok, you understand that you're 6 A No. If I didn't understand a question, 7 testifying under oath today? 7 you can't assume that I understand a question. 8 A Of course. 8 Q Thank you. That's not what I was saying, 9 Q You understand that means you have to 9 so this is a perfect example. Let's start again. 10 testify truthfully? 10 If you don't understand my question, will 11 A Correct. 11 you tell me? 12 Q And you understand that you may not omit 12 A I will not. If I don't understand your 13 information that you know that is called for by the 13 question, I will not tell you, because I didn't 14 question, correct? 14 understand. 15 A Of course. 15 Q Will you tell me that you don't understand 16 my question? 17 A Yes, of course. 18 Q And if I ask you a question and you do not 19 tell me that you don't understand, can I assume that 20 you do understand my question? 21 MR. MAJOR: Objection to form. 22 THE WITNESS: Of course. That works. 23 BY MR. LUFT: 24 Q Great. Okay.

1 appearing on behalf of yourself and for the entity 2 Greenwich Land today? 3 A Yes. 4 Q If in answering a question your answer 5 would differ from what -- your answer as an 6 individual, as opposed to your answer on behalf of 7 Greenwich Land, will you let me know? 8 Q Other than Mr. Major and Mr. Intrater, 8 A Yes. 9 Q Ms. Ngok, what did you do to prepare for 9 have you discussed this deposition with anyone else? 10 your deposition today? 10 MR. MAJOR: Objection to form. 11 A I did. I prepared with my attorneys. 11 THE WITNESS: No. 12 Q And who are your attorneys today? 12 BY MR. LUFT: 13 THE WITNESS: I'm sorry, Gentlemen. I 13 Q Other than Mr. Intrater and Mr. Major, 14 can't pronounce your names. 14 have you discussed this case with anyone else? 15 But these two gentlemen sitting right here 15 MR. MAJOR: Objection to form. 16 (indicating). 16 THE WITNESS: No. 17 BY MR. LUFT: 17 BY MR. LUFT: 18 Q Mr. Major and -- 18 Q In preparing for this deposition, did you 19 MR. LUFT: Intrater? Is that 19 review any documents? 20 MR. INTRATER: That's great. Perfect. 20 A I did. 21 THE WITNESS: I'm sorry. I don't have any 21 Q What documents did you review? 22 mental note of any English name. Sorry about 22 A The same documents I review for the last 23 that. 23 deposition. 24 MR. LUFT: That's fine. 24 Q Can you remind me what documents those 25 For the record can we agree that she has 25 were?

pointed to Mr. Major and Mr. Intrater as her 1 Page 16 A Some -- something like some sort of bank 2 counsel who she met with? 2 documents. But to be very frank with you, I don't

3 MR. MAJOR: Yes. 3 even understand them. 4 MR. LUFT: Okay. 4 Q Do you recall what bank documents they 5 THE WITNESS: (In English) Sorry about 5 were? 6 that. 6 A I can't remember. 7 MR. LUFT: That's okay. 7 Q Other than preparing for this deposition, 8 THE WITNESS: Okay. 8 had you ever seen these bank documents before? 9 BY MR. LUFT: 9 A No. 10 Q How many times did you meet with them in 10 Q Were they bank documents related to your 11 preparation for this deposition? 11 personal bank accounts? 12 A Twice. 12 MR. MAJOR: Objection to form. 13 Q When did you meet with them? 13 THE WITNESS: No. 14 A I can't remember specifically when, but it 14 BY MR. LUFT: 15 happens within a month. 15 Q Were they bank accounts related to 16 Q How long did you meet with them? 16 Greenwich Land's bank accounts? 17 A It could range from one to two hours or 17 MR. MAJOR: Objection to form. 18 two to three hours. 18 THE WITNESS: They are not statements. I 19 Q When you met with your attorney, 19 don't know what they are. I am not even -- I'm 20 Mr. Intrater or Mr. Major, was there anyone else 20 not able to tell what they are. 21 present? 21 BY MR. LUFT: 22 A Interpreters -- interpreter. 22 Q Can you give me your best description of 23 INTERPRETER: Sorry. 23 those bank documents? 24 BY MR. LUFT: 24 A Okay. I don't know if they are even a 25 document -- they are even a document. I have seen

them. I can't recall. I can't tell the content of 1 Page 19

2 it. 2 the witness not to answer on the grounds of 3 Q But they were documents that you looked at 3 privilege. 4 to prepare for this deposition? 4 MR. LUFT: On what grounds can that be 5 MR. MAJOR: Objection to form. 5 privileged? I'm asking just the name of who's 6 THE WITNESS: Correct. 6 the person who made the decision. 7 MR. LUFT: Mr. Major, I don't believe 7 MR. MAJOR: The decision that you're 8 we've received any bank documents. Have they 8 referring to -- first of all, you're 9 been -- the documents the witness is referring 9 presupposing that the decision was the decision 10 to, have they been produced to us? 10 of Greenwich Land. But the contemplation of 11 MR. MAJOR: I don't know what documents 11 hiring or separating from counsel is 12 the witness is specifically referring to, but 12 privileged. 13 we have produced bank records to you, 13 MR. LUFT: I'm not asking about the 14 specifically from The Bank of Princeton. I 14 content; I just want to know who was the person 15 know that my firm handled that production. I 15 who made the decision. That's not privileged. 16 know the law firm of Updike, Kelly & Spellacy, 16 It doesn't call for legal advice or anything 17 I believe, produced some bank records to you in 17 else. 18 advance of the just closed Rule 2004 exam. I 18 MR. MAJOR: The decision of either hiring 19 assume that's what the witness is referring to, 19 or separating from counsel is a privileged 20 but I don't know. 20 matter. 21 MR. LUFT: Okay. I'll just ask that on a 21 MR. LUFT: Correct, but the person who -- 22 break you confer with her, and if there are 22 the name of the person who decided that is not

24 documents that we haven't received yet, if you just let us know and produce them, okay? 23 24 privileged.

25 MR. MAJOR: Yes. And I do not think there 25 question necessarily calls for discussions with

1 are documents that we have that you don't have 1 counsel.

3 yet, but I will certainly triple-check that

3 MR. LUFT: No, it just calls for the name,

4 MR. LUFT: Terrific. 4 Greenwich Land's representative; I'm free to 5 BY MR. LUFT: 5 ask her who's the person who made the decision. 6 Q Other than the documents you've referred 6 That's not a privileged question. 7 to as the "bank documents," are there any other 7 MR. MAJOR: You can ask questions about 8 documents you looked at to prepare for this 8 decisions that Greenwich Land made on other 9 deposition? 9 matters, but not on counsel. 10 A There must be some, but I can't remember 10 MR. LUFT: Okay. I disagree with you, I 11 what they are. 11 think you're obstructing, and you haven't given 12 Q When was the last time you reviewed these 12 me any explanation why the name of an 13 documents? 13 individual calls for the provision of legal 14 A Probably approximately three weeks ago, 14 advice. 15 but I don't remember specifically when. 15 BY MR. LUFT: 16 Q Okay. Ms. Ngok, when I deposed you in 16 Q Ms. Ngok, are you going to follow your 17 January, you were represented by a different lawyer 17 counsel's instruction? 18 from a different law firm, correct? 18 A Correct. 19 A Correct. 19 Q Ms. Ngok, were you the person who made the 20 Q And that was Mr. Goldstein from the Updike 20 decision to replace Updike Kelly with Mr. Major's 21 Kelly firm, correct? 21 firm?

23 MR. MAJOR: Objection to form. Instruct the witness not to answer on the grounds of

24 Q Who made the decision at Greenwich Land to change counsel from Updike Kelly to Mr. Major's 24 privilege.

1 BY MR. LUFT: 1 before you signed the supplemental responses to the 2 Q Ms. Ngok, are you going to follow your 2 interrogatories? 3 counsel's direction? 3 A I did. 4 A Correct. 4 Q And before signing did you agree that all 5 Q Ms. Ngok, I'm going to ask the court 5 the information included in the document was 6 reporter to mark as Ngok Deposition Exhibit 3 a copy 6 accurate and true? 7 of defendant Greenwich Land, LLC's supplemental 7 MR. MAJOR: Objection to form. 8 responses and objections to the first set of 8 THE WITNESS: I believe so. 9 interrogatories by plaintiff Luc Despins, the 9 BY MR. LUFT: 10 Chapter 11 trustee. 10 Q Ms. Guo, if we look at response to

12 BY MR. LUFT: 12 INTERPRETER: Ms. -- did you say, 13 Q Ms. Ngok -- 13 "Ms. Guo"? 14 (A discussion was held off the 14 MR. LUFT: Sorry. Ms. Ngok. 15 stenographic record.) 15 INTERPRETER: Sorry. Okay. 16 BY MR. LUFT: 16 THE WITNESS: Okay. 17 Q Ms. Ngok, I've put in front of you as 17 BY MR. LUFT: 18 marked as Exhibit 3 a document titled "Defendant 18 Q -- there's a sentence that says "Greenwich 19 Greenwich Land, LLC's Supplemental Responses and 19 Land's sole purpose is to own a residential property 20 Objections to the First Set of Interrogatories by 20 in Greenwich, Connecticut." 21 Plaintiff Luc Despins," the Chapter 11 trustee. Do 21 A Correct. 22 you see that? 22 Q Is that true? 23 MR. MAJOR: Objection to form. 23 A Correct. 24 THE WITNESS: Yes, I see it. 24 Q So when you say "Greenwich Land's sole 25 25 purpose is to own a residential property in

1 BY MR. LUFT: 1 Greenwich, Connecticut," what do you mean? 2 Q If you turn to the last page of the 2 MR. MAJOR: Objection to form. 3 document, you'll see a signature line for Greenwich 3 THE WITNESS: I don't understand this 4 Land. It says by Hing Chi Ngok, "Title: Sole 4 question. Can you please clarify? 5 Member." 5 BY MR. LUFT: 6 INTERPRETER: Sorry. 6 Q My question is simply there's a statement 7 THE WITNESS: Yes. 7 in the interrogatory, and I just want to understand 8 BY MR. LUFT: 8 what Greenwich Land meant by that statement. 9 Q Do you see that, Ms. Ngok? 9 MR. MAJOR: Objection to form. 10 A I see it. 10 THE WITNESS: Can you please tell me which 11 Q And whose signature is that? 11 statement? 12 A It looks like my signature, but I cannot 12 BY MR. LUFT: 13 be certain that it is mine. 13 Q Sure. It is on the response to 14 Q The date of this document is September 9, 14 Interrogatory No. 1. There's a sentence that says 15 2023, two days ago. 15 "Greenwich Land's sole purpose is to own a 16 A Two days ago? 16 residential property in Greenwich, Connecticut." 17 Q Yes. 17 A Correct. 18 Do you recall signing responses -- 18 Q And my under -- my question is what does 19 interrogatory responses two days ago? 19 Greenwich Land mean by that statement? 20 A I believe so. 20 MR. MAJOR: Objection to form. 21 Q And the document indicates that you were 21 THE WITNESS: I don't know what you mean 22 provided a translation of this English document into 22 by that. This company owns properties, isn't 23 Mandarin; is that correct? 23 it? 24 A Correct. 25 Q Did you read that Mandarin translation Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 9 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 10 of 52 Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 10 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 11 of 52

THE WITNESS: I don't know about that too. 1 Page 31 discussing?

2 BY MR. LUFT: 2 MR. MAJOR: Objection to form. 3 Q Since Greenwich Land has been founded, 3 THE WITNESS: I do not know. 4 who -- what individuals have had the right to spend 4 BY MR. LUFT: 5 money on behalf of Greenwich -- or let me strike 5 Q Do you have any idea where Greenwich Land 6 that. 6 gets the money from that you use to pay for personal 7 Since Greenwich Land has been founded, 7 expenses unrelated to the two houses we've been 8 what individuals have had the right to spend money 8 discussing? 9 from Greenwich Land accounts? 9 MR. MAJOR: Objection to form. 10 MR. MAJOR: Objection to form. 10 THE WITNESS: I do not know. 11 THE WITNESS: I don't know. 11 BY MR. LUFT: 12 BY MR. LUFT: 12 Q Where does Greenwich Land get the money 13 Q Ms. Ngok, do you have the right to spend 13 from that it uses to pay for expenses related to the 14 Greenwich Land's money? 14 two houses we've been discussing? 15 MR. MAJOR: Objection to form. 15 MR. MAJOR: Objection to form. 16 THE WITNESS: I believe I do. 16 INTERPRETER: Can the interpreter 17 BY MR. LUFT: 17 reinterpret? 18 Q What are you allowed to spend Greenwich 18 THE WITNESS: I do not know. 19 Land's money on? 19 BY MR. LUFT: 20 MR. MAJOR: Objection to form. 20 Q Who at Greenwich Land would know where it 21 THE WITNESS: It's just like the family 21 gets the money it spends? 22 day-to-day expenditures. 22 MR. MAJOR: Objection to form. 23 BY MR. LUFT: 23 THE WITNESS: I do not know. 24 Q Related to the properties or any 24 BY MR. LUFT: 25 expenditures related to the family? 25 Q Who at Greenwich Land would know who

1 MR. MAJOR: Objection to form. 1 provides the money that goes into Greenwich Land's 2 THE WITNESS: It's like the family 2 bank accounts? 3 expenditure. For instance, like landscaping, 3 MR. MAJOR: Objection to form. 4 utilities. 4 THE WITNESS: I'm not clear about that. 5 BY MR. LUFT: 5 BY MR. LUFT: 6 Q How about personal expenses not related to 6 Q Do you know who provides the funds that 7 upkeep of the house for -- let me just stop there. 7 have been placed into Greenwich Land's bank accounts 8 MR. MAJOR: Objection to form. 8 since its -- since they've been open till today? 9 THE WITNESS: Sometime, yes. 9 MR. MAJOR: Objection to form. 10 BY MR. LUFT: 10 THE WITNESS: I do not know. 11 Q What personal expenses not related to the 11 BY MR. LUFT: 12 house do you spend Greenwich Land money on? 12 Q Ms. Guo, do any -- sorry. Let me strike 13 MR. MAJOR: Objection to form. 13 that. Let's get some clarity. 14 THE WITNESS: Nothing too specific. 14 15 Ms. Ngok, my understanding is that your last name is spelled N-G-O-K; is that correct?

16 BY MR. LUFT: Q Give me your best recollection of personal 16 A Correct. 17 expenses not related to the upkeep of the two houses 17 Q In response -- if we look at Exhibit 3, in 18 you've mentioned for which you've used Greenwich 18 response to our interrogatories, all the references 19 Land money. 19 are either to a "Ms. Guo" or a "Mrs. Guo." So my 20 MR. MAJOR: Objection to form. 20 first question is are you -- is the references to 21 THE WITNESS: I don't remember. 21 "Mrs. Guo" to be understood to be a reference to 22 BY MR. LUFT: 22 you, Ms. Ngok? 23 Q What's the source of Greenwich Land's 23 A Correct. 24 money that is used to pay for personal expenses not 24 Q And are the references to "Ms. Guo" also 25 related to the upkeep of the two houses we've been 25 intended to be a reference to you, Ms. Ngok? Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 11 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 12 of 52

Page 33 1 A Correct. 2 Q Ms. Guo -- sorry. Let me strike that. 3 (Witness speaking Mandarin.) 4 INTERPRETER: She said she couldn't hear 5 me clear. 6 You okay? 7 (A discussion was held off the 8 stenographic record.) 9 BY MR. LUFT: 10 Q Ms. Ngok, have you ever received money 11 from an entity called Hudson Diamond New York? 12 A I don't remember. 13 Q I'm going to ask the court reporter to 14 mark as Ngok Deposition Exhibit 4 a document Bates 15 stamped 19 (Exhibit 4 was marked for I.D.) 20 MR. MAJOR: Objection to form. To the 21 extent that the question is to ask the witness 22 to read the document and state whether she can 23 identify it, I just want to note for the 24 record, she does not read English so would not 25 have the ability to answer that question. Page 34 1 MR. LUFT: Why don't you let me ask my 2 question and then object to it? 3 MR. MAJOR: Okay. I just didn't know if 4 you -- if your statement was a question. It's not a 7 question, right? 8 BY MR. LUFT: 17 BY MR. LUFT: 18 Q Ms. Ngok -- 19 A Yes. 20 Q -- 22 MR. MAJOR: Objection to form. 23 THE WITNESS: I do not know. 24 BY MR. LUFT: 25 Q Page 35 1 2 MR. MAJOR: Objection to form. 3 THE WITNESS: I do not know. 4 BY MR. LUFT: 5 Q Tell me everything you know about Hudson 6 Diamond New York. 7 A I've never heard of this company before. 8 Q 11 MR. MAJOR: Objection to form. 16 BY MR. LUFT: 19 A Yes. 20 Q 22 MR. MAJOR: Objection to form. 23 THE WITNESS: Page 36 1 MR. LUFT: Okay. Why don't we take a 2 short break? 'Cause I'm going to go for a 3 while after that. 4 MR. MAJOR: Sure. 5 VIDEOGRAPHER: Okay. We're off the 6 record. The time is 11:25. 7 (A recess was taken.) 8 VIDEOGRAPHER: We're back on the record. 9 The time is 11:46. 10 (A discussion was held off the 11 stenographic record.) 12 BY MR. LUFT: 22 MR. LUFT: The document's upside-down for 23 the witness. 24 BY MR. LUFT: 25 Q Ms. Ngok, before you Exhibit 5, as I said, Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 12 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 13 of 52 Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 13 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 14 of 52

BY MR. LUFT:

BY MR. LUFT:

BY MR. LUFT:

Q Ms. Ngok, what address does Greenwich Land

use for its banking?

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

THE WITNESS: I do not remember.

BY MR. LUFT:

BY MR. LUFT:

Q Ms. Ngok, what is the name of the company

that owns your home?

A Let me think about it.

the name of the company, so I used to use some

Chinese similar pronunciation to write in Chinese

character. It's called Guan Lei Chi.

INTERPRETER: G-U-A-N L-E-I C-H-I.

BY MR. LUFT:

Q Is that in pinyin? Is that in pinyin?

A Yes, it is pinyin.

it down in Chinese character; the interpreter

made into pinyin.

MR. LUFT: Okay.

THE WITNESS: (In English) Sorry.

BY MR. LUFT:

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MR. MAJOR: There's no question.

BY MR. LUFT:

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

INTERPRETER: Thank you.

MR. LUFT: Of course.

BY MR. LUFT:

A Okay.

BY MR. LUFT:

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MR. MAJOR: Objection to form.

THE WITNESS: I can't tell. I can't read.

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: I do not know why.

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

THE WITNESS: I don't know. I can't -- I 17 BY MR. LUFT:

BY MR. LUFT:

a fact not established.

MR. LUFT: What fact is that?

question -- alleged facts in your question.

MR. MAJOR: Objection to form.

documents, Mr. Major, showing that transfer,

Q Okay.

right? What more foundation could we have?

using English language documents even though

you know she only reads Mandarin and trying to

ask questions off of these documents. So I

objected to the question; I didn't instruct the

witness not to answer. But it's an improper

question, so I object to it.

records and the statements of your client.

That they happen to be in English and you put

up a witness that doesn't speak English is your

choice, but I can only use the records of the

company.

documents we produced to you, based on the

Bates numbering.

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reason for the objection.

she is the only person left at Greenwich Land,

so if she doesn't know, the answer is obvious.

But I can't -- I mean, I guess if you want

me to, I could try to go back if you're asking

me the basis for all of my objections.

MR. LUFT: No.

MR. MAJOR:

a lot of questions.

Q Yes, ma'am. The first line and then the 10 MR. LUFT:

questions because you think the answer is

MR. MAJOR:

objections is it was a nonsensical question:

You're asking a witness who didn't know a fact

MR. LUFT:

representative for the company; this is a house

that the company alleges that it owns.

think there's anything crazy about asking them

who would know what law firm -- who hired the

law firm that represented them.

So we'll move on.

extremely judicious when I object so that I

don't interfere with your transcript. And

circumspect in my objections.

MR. LUFT: Okay.

my objections.

BY MR. LUFT:

since you've come to the United States? Meaning the

addresses.

the witness answered the question that she did 14 A When I first came to the United States, I

not know. We've given you interrogatory 15 live in town.

responses explaining that Mrs. Guo is the only 16 Q "In town" meaning Manhattan?

person left at Greenwich Land, and then your 17 A Correct.

next question was who at Greenwich Land would 18 Q At the Sherry Netherland hotel?

INTERPRETER: Sheraton?

MR. LUFT: Sherry Netherland.

number of grounds, including you're asking a 21 THE WITNESS: Correct.

witness who doesn't -- who just said she 22 BY MR. LUFT:

doesn't know a fact if she knows who knows that

fact that she doesn't know. So the question

doesn't make a lot of sense to me. That's one

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MR. MAJOR: Objection to form.

THE WITNESS: I do not know why.

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

MR. LUFT: And I will mark as Exhibit 14 a

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS:

Okay.

BY MR. LUFT:

Q And if I ask you to turn to page ending in

MR. MAJOR: I don't think she'll know what

a Bates number is. I can flip it for her or --

okay.

INTERPRETER: I can help her.

MR. MAJOR: Okay, please.

THE WITNESS: I'm on it.

BY MR. LUFT:

Q Oh, sorry. Yes, correct, ma'am. You're 23

right.

witness can't read the words.

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if Greenwich Land holds any ownership interest in Page 87

2 MR. LUFT: I understand. Not a problem. 2 Saraca Media.

A I do not know.

MR. MAJOR: Objection to form.

THE WITNESS: I am not sure about that.

BY MR. LUFT:

A I do not know.

19 BY MR. LUFT: 20 Q Ms. Ngok, do you have any ownership 21 interest in Saraca Media? 22 A No. I don't know. 23 Q Ms. Ngok, do you have any ownership 24 interest in Hudson Diamond New York?

MR. MAJOR: Objection to form.

1 Q My question, I'll ask it in two ways: Do 1 THE WITNESS: I don't know. 2 you personally, Ms. Ngok, have any ownership 2 BY MR. LUFT: 3 interest in the entity named Hudson Diamond New 4 York? 5 A I don't remember. I don't even understand 6 what he means by that. 7 Q Ms. Ngok, does Greenwich Land have any 8 ownership interest in Hudson Diamond New York? 9 A I do not know. 10 Q Does Greenwich Land have any ownership 11 interest in Saraca Media? 12 A I'm a little confused. I really don't 13 know. 14 Q That's okay. That's no worries.

16 should -- you can take her out. 17 MR. LUFT: Okay. Let's take a break. Off 18 the record. Let's go off the record before -- 19 VIDEOGRAPHER: The time is 3:20. Off the

22 VIDEOGRAPHER: We're back on the record. 22 just email a copy of it?

COURT REPORTER: Sure.

Q Ms. Ngok, before we broke, I had asked you 25 we'll do.

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1 MR. MAJOR: I could also print it for you 1 MR. MAJOR: Objection to form. 2 today. 2 THE WITNESS: I don't remember. 3 MR. LUFT: That would be great too. I'm 3 BY MR. LUFT: 4 happy to do it either way. 4 Q Okay. No problem. 5 MR. MAJOR: Email it to me and I'll print 5 6 it. 7 MR. LUFT: Perfect. Okay. 8 BY MR. LUFT: 8 A I don't remember.

9 Q Ms. Ngok, earlier you told me that 9 Q 10 Greenwich Land sold the house at 33 Ferncliff Road 11 in Greenwich, Connecticut. Do you recall that? 12 A Yes, I remember. 13 Q Okay. And do you -- and do you recall 13 A I don't remember.

22 THE WITNESS: I don't remember. 22 BY MR. LUFT: 23 MR. LUFT: Okay. Let's mark as 23 Q That's okay.

2 A I don't remember.

6 A I have gone to view the house before.

were marked for I.D.) 7 Q I appreciate -- that's helpful.

9 Q Ms. Ngok, my first question is simple: 13 A Where is the dates? 13 A It was me. 14 Q 14 Q Okay. And when did you make that 15 decision? 16 A I don't remember very clearly.

17 MR. MAJOR: Objection to form. 17 Q Okay. 18 BY MR. LUFT:

25 A I don't remember. Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 26 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 27 of 52

2 BY MR. LUFT:

5 Q 5 Q Understood. 9 A I do not remember. 10 Q Okay. I'm going to show you a document 10 MR. MAJOR: Objection to form. 11 that I'll ask the court reporter to mark as 11 THE WITNESS: Okay. 12 BY MR. LUFT: 12 Exhibit 18, which has a control number on it of 13 00016119. That number is the number for the entire 13 Q 14 document. It was produced to us without Bates 15 stamps, so just for clarity, we put a control number 16 on it. 16 MR. MAJOR: Objection to form. 17 17 THE WITNESS: I really do not remember. 18 BY MR. LUFT: 19 Q Okay. Let me show you another document. 20 MR. LUFT: Let's mark as Exhibit 19 -- 21 (Exh bit 18 was marked for I.D.) 21 COURT REPORTER: Sorry. 22 THE WITNESS: Okay. 22 MR. LUFT: Sorry. 23 BY MR. LUFT: 23 -- a document bearing the control stamp 24 Q Ms. Ngok, do you recognize this document? 24 CTRL00016119, which purports to be 25 MR. MAJOR: Objection to form.

1 THE WITNESS: I -- I'm sure I'm not able 1 2 to recognize it. 3 BY MR. LUFT: 3 (Exhibit 19 was marked for I.D.) 4 Q Okay. Well, let's see if we can find 4 THE WITNESS: Okay. 5 something you recognize. 5 MR. MAJOR: Object 6 6 BY MR. LUFT:

12 A Can you point it out to me which page it

is? 14 Q Of course, ma'am. I can show you on mine.

16 MR. LUFT:

19 (indicating)? 20 BY MR. LUFT:

22 INTERPRETER: Sorry. 23 BY MR. LUFT:

25 THE WITNESS:

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A I don't remember.

Q Okay. You can put that aside.

A Okay.

document with the control number CTRL00016119.

Again, this is a multipage document that was

produced to us without Bates stamps, so we just

put it on there.

THE WITNESS: No, it's not.

MR. LUFT: It's -- I don't want to say it,

'cause I assume you don't want her social

MR. MAJOR:

BY MR. LUFT:

A You mean this one (indicating)?

Q Yes, ma'am.

THE WITNESS: Okay.

BY MR. LUFT:

of you.

A Where did you see page No. 7?

MR. LUFT: Completely fair.

English, I don't understand English, and I

BY MR. LUFT:

MR. MAJOR: Can I just flip to it for her?

MR. LUFT: I -- I did. She has it.

THE WITNESS: I am on it, but I don't know

if that's the correct one.

BY MR. LUFT:

Q That's the correct -- you're on the same

page as me.

remember.

Q Okay.

THE WITNESS: No, it is not either.

A It's an apartment? It's an apartment? Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 28 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 29 of 52

MR. MAJOR: Objection to form.

THE WITNESS: Okay. I see it.

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: Yes.

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

MR. MAJOR: Objection.

THE WITNESS: I don't know.

BY MR. LUFT: reporter to mark as Exhibit 21 another document

BY MR. LUFT:

answer to that question?

MR. MAJOR: Objection to form.

THE WITNESS: Can you repeat?

MR. LUFT: Sure.

BY MR. LUFT:

answer to that question?

MR. MAJOR: Objection to form.

THE WITNESS: Me too don't know.

be -- it's warm in here. How are you feeling?

And do you need a break?

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THE WITNESS: I don't remember.

BY MR. LUFT:

4 Q Ms. Ngok, you previously told me you have 5 a debit card for Greenwich Land -- for a Greenwich 6 Land account? 7 A I don't know what it is. It's -- I call 8 it the "consumer" card. I can use it to consume 9 things, but I don't know what you call it. 10 Q Ms. Ngok, that card is issued by Bento 10 MR. MAJOR: Objection to form.

THE WITNESS: I don't remember clearly. 12 MR. MAJOR: I've just been advised that 12 BY MR. LUFT: 13 there may have been a part missing from the 13 Q Okay. 14 translation. She said something about not

15 taking money out of the card.

17 (The reporter requested clarification.) 18 MS. SONG: So she just mentioned that she 18 A I do not know. 19 never tried to take money out using that Bento 19 Q Okay. In the interest of trying to save 20 card and that she just used it to make some 20 some time, I'm going to ask you a question that

consolidates a number of these exhibits. But if you 22 MR. LUFT: You can't take down her 22 need me to break any of it up, please let me know. 23 testimony.

25 reinterpret?

1 MR. LUFT: That's perfectly fine. 2 INTERPRETER: Yeah, that's the proper way 3 to do it.

5 THE WITNESS: Okay. I don't know what it 6 is called. I call it the "consumer" card. I 7 can use it to consume -- buy things, but I 8 never withdrawal any cash out of it. But I 9 don't know what you call it. 10 MR. LUFT: Okay. Everyone good with that? 11 That's okay? Okay. 12 BY MR. LUFT: 13 Q Okay.

24 INTERPRETER: I'm sorry. 25 MR. MAJOR: Objection to form.

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the record; you don't have to do anything with them 1

right now.

that or?

that.

As Exhibit 35, the next in that series, 9 MR. LUFT: Okay.

of it.

MR. LUFT: You can just tell her that I --

second.

THE WITNESS: Okay.

BY MR. LUFT:

Q Ms. Ngok, I'll ask you to turn to -- if

you could just pull out Exhibit 22 and Exhibit 33.

INTERPRETER: Sorry.

MR. LUFT: Go ahead.

THE WITNESS: Yes.

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: I see it.

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: Which date?

MR. LUFT:

THE WITNESS: Yes, I see it.

BY MR. LUFT:

Q Okay. In the interest of trying to save

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BY MR. LUFT:

Q Ms. Ngok, who had the authority to write

checks on behalf of Greenwich Land's bank account at

The First Bank of Greenwich?

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

authorize the writing of checks from Greenwich

Land's bank account at The First Bank of Greenwich?

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

Q Ms. Ngok, are you familiar with a company

called Gypsy Mei -- M-E -- "Mei" is spelled M-E-I,

same as your daughter's -- Food Service, LLC?

A I am not familiar with this.

Exhibit 45 a document bearing the Bates stamp

HR0003000 through 32, titled "Minute Book of

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

Q Okay. We're going to come back to these,

but for now you can put them to the side for a

second.

BY MR. LUFT:

reporter to mark as Exhibit 44 a document produced

BY MR. LUFT:

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1 MR. MAJOR: That's fine. 1 Max Krasner resigned from his position at Greenwich 2 BY MR. LUFT: 2 Land. Are you aware of those statements to the 3 Q Okay. And specifically, Interrogatory 3 court? 4 No. 6 asks Greenwich Land to "Identify all employees 4 A I do not know. 5 of Greenwich Land, including directors and officers, 5 MR. MAJOR: Just objection. I just want 6 and the role of each identified individual." 6 to -- it's fine, the answer is out. But just 7 And in response Greenwich Land stated that 7 because it dealt with the court, I was going to 8 you are presently the sole member of Greenwich Land 8 put in an objection regarding privilege. But 9 and Greenwich Land presently has no separate 9 she's already answered it and it didn't reveal 10 manager, officers, or employees. And then it says 10 any privileged communication. So I pardon the 11 Greenwich Land previously had officers. Yvette 11 interruption, but I just wanted to note that 12 Wang, Daniel Podhaskie, and Max Krasner previously 12 since I had already interrupted, just telling 13 served in the roles of vice president of Greenwich 13 you why. 14 Land. All of them resigned before the end of 2022? 14 (A discussion was held off the 15 INTERPRETER: End of 2022? 15 stenographic record.) 16 MR. LUFT: Yes, that's what it says. 16 THE WITNESS: Okay. 17 BY MR. LUFT: 17 BY MR. LUFT: 18 Q Ms. Ngok, was that information correct 18 Q Ms. Ngok, if it helps refresh your 19 when you signed and verified these interrogatories? 19 recollection, if you look at page 6 of your 20 MR. MAJOR: Objection to form. 20 interrogatories, under "Right to Supplement," it 21 THE WITNESS: Yes. 21 references language related to Max Krasner resigning 22 BY MR. LUFT: 22 on November 5, 2022. Does that refresh your 23 Q Okay. So is it fair to say that, to 23 recollection that someone by the name of Max Krasner 24 Greenwich Land's knowledge, Chunguang Han was never 24 resigned from Greenwich Land on November 5, 2022? 25 a manager, officer, or employee of Greenwich Land? 25 MR. MAJOR: Objection to form.

MR. MAJOR: Objection to form. 1 Page 148

2 THE WITNESS: I've never heard about it. 2 stenographic record.) 3 BY MR. LUFT: 3 THE WITNESS: Which page? 4 Q Okay. Is it also fair to say that your 4 BY MR. LUFT: 5 daughter, Mei Guo, has also never been a manager, 5 Q Page 6. 6 director, or officer of Greenwich Land -- or 6 A I can't read it. 7 employee. 7 Q That's okay. 8 MR. LUFT: Sorry. 9 INTERPRETER: Sorry. 10 THE WITNESS: How do I put it? Well, I 11 don't know. 12 BY MR. LUFT:

14 interrogatory -- certified -- signed the 15 interrogatories to certify the answer, did Greenwich 16 Land have any reason to believe that Mei Guo has 17 been an employee, director, or officer of Greenwich 18 Land, such that she should be included in the 19 answer? 20 MR. MAJOR: Objection to form. 21 THE WITNESS: I'm not sure about that. 21 BY MR. LUFT: 22 BY MR. LUFT: 22 Q Okay. Do you see if, when we look at the 23 Q Okay. And, Ms. Ngok, Greenwich Land has 23 exhibits -- 24 filed documents with the court in this case stating 24 INTERPRETER: Okay. The interpreter would 25 that on November 5, 2022, a person by the name of 25 like to rectify the answer. The answer is "I'm

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MR. MAJOR: Objection to form.

THE WITNESS:

BY MR. LUFT:

MR. MAJOR: Objection to form.

MR. LUFT: And I'll ask the court reporter 17 THE WITNESS:

BY MR. LUFT:

our most recent one, which is from -- well, let me

strike that. Let me find one that may stick out a

bit more.

And -- well, let me first -- let me strike

that.

(The following testimony was deemed highly

BY MR. LUFT:

document.

BY MR. LUFT:

BY MR. LUFT:

again, sir?

MR. LUFT: You could just strike it.

BY MR. LUFT:

want to have any attorney-client privileged

communications put on the record. So I just

want to -- I don't know what the best thing to

do is, but I'd like to maybe -- and I have no

idea what the rest of the answer was, so I

don't know if it just a passing reference or

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BY MR. LUFT:

24 BY MR. LUFT: 25 Q Ms. Ngok, are you familiar with the

THE WITNESS: I don't know. 1 restaurant Henry Cipriani, which is in the same BY MR. LUFT: 2 building as the Sherry Netherland apartment? 3 A I am not familiar.

13 BY MR. LUFT: 14 Q Ms. Ngok, have you personally ever eaten 15 at Henry Cipriani [sic], which is located in the 16 same building as the Sherry Netherland hotel? 17 A Yes, I have dined in the same -- in that

18 restaurant before, but that was years back when I 19 first came to the United States, probably in the 20 year of 2017.

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THE WITNESS: I only have breakfast in the

restaurant when I first came to the United

States back in 2017.

BY MR. LUFT:

opened bank accounts and signed documents on behalf

of Greenwich Land, correct?

MR. MAJOR: Just objection to form.

I'm sorry.

THE WITNESS: I don't know about that.

BY MR. LUFT:

BY MR. LUFT:

A I don't remember.

BY MR. LUFT:

form.

THE WITNESS:

BY MR. LUFT:

MR. MAJOR: Objection to form.

THE WITNESS: I don't remember.

Exhibit 52?

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later?

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

BY MR. LUFT:

A I do not know.

Q Ms. Ngok, are you familiar with someone by

MR. LUFT: Okay. Let's mark as Exhibit 55 10 the name of Dinggang Wang?

the name, sir?

W-A-N-G.

THE WITNESS: I am not familiar.

BY MR. LUFT:

A I do not know.

Q Okay. Ms. Ngok, I'm going to have marked

as Exhibit -- what are we up to, 56? -- 56 documents

entitled "Residential Lease Renewal Agreement,"

between Greenwich Land, LLC, and Wang Dinggang.

(A discussion was held off the record.) 1 BY MR. LUFT:

BY MR. LUFT:

Q Ms. Ngok, do you recognize this document?

A I don't remember.

Q Did you ever authorize Greenwich Land to

lease 33 Ferncliff to a man named Dinggang Wang?

A I don't remember.

reporter mark as Exhibit 57 a copy of a document

entitled "Residential Lease Renewal Waiver

Agreement," which is an agreement between, again,

THE WITNESS: I really do not know why. 11 Greenwich Land, LLC, and Mr. Wang Dinggang dated

October 9, 2020.

BY MR. LUFT:

Q Ms. Ngok, who authorized Greenwich Land to

enter into this agreement with Mr. Dinggang Wang

related to he and his family living at 33 Ferncliff?

MR. MAJOR: Objection to form.

THE WITNESS: I do not understand your 19 THE WITNESS: I'm not sure.

BY MR. LUFT:

Land's business to do media consulting?

A I'm not sure.

Q You're the sole member of Greenwich Land.

Are you aware of any media business that Greenwich

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INTERPRETER: Can the interpreter clarify?

2 I was still interpreting the first question; 3 MR. LUFT: Let's mark as Exhibit 59 a 3 you asked a second question. Can the 4 document titled "Retail Fuel Delivery and 4 interpreter reinterpret? 5 Service Agreement," dated February 6, 2020, 5 MR. LUFT: And then she answered the 6 under the name of Ho Wan Kwok for the address 6 question, correct? 7 of 30 Ferncliff Road [sic]. 7 INTERPRETER: Yes, she answered the 8 (Exhibit 59 was marked for I.D.) 8 question. She said yes. 9 (A discussion was held off the 9 MR. LUFT: To my first question, and

11 MR. LUFT: Guys, I have to ask for a copy 11 MR. MAJOR: I don't know -- I disagree 12 back. Sorry. Thank you. 12 with that. 13 BY MR. LUFT: 13 MR. LUFT: You can't disagree. She's the 14 Q Ms. Ngok, this is a fuel delivery 14 interpreter, Chris. She's telling you that's 15 agreement -- 15 what happened. 16 MR. MAJOR: Wait. Hold on. The -- you 16 MR. MAJOR: I'm talking about the order of 17 just took our copies back and -- 17 the questions. 18 MR. LUFT: I didn't take your copies. You 18 MR. LUFT: Do you speak Chinese? 19 have two lawyers; I gave you one. You guys 19 MR. MAJOR: First of all, that's not a 20 still have one, right? 20 language but -- and you've been saying that all 21 MR. MAJOR: No, we gave them both back. 21 day but 22 You said it was the wrong document. 22 MR. LUFT: It's not? No, there are two 23 MR. LUFT: No, I just needed a copy. 23 dialects I think you're referring to, but 24 MR. MAJOR: Ah, okay. 24 there's obviously a language of Chinese, and 25 25 Mandarin is commonly referred to as "Chinese."

1 BY MR. LUFT: 1 Let's not waste time. 2 Q Ms. Ngok, this is a retail fuel delivery 2 MR. MAJOR: Hold on. 3 and service agreement dated February 6, 2020, for 3 MR. LUFT: Chris, I understand there's ten 4 the address 33 Ferncliff Road, Cos Cob, Connecticut, 4 minutes; I understand you're trying to run it 5 under the name of Ho Wan Kwok. 5 out all of a sudden with all these -- 6 MR. MAJOR: Objection to form. 6 MR. MAJOR: I'm not trying to run it out. 7 BY MR. LUFT: 7 You asked a compound question; I'm objecting to 8 Q 33 Ferncliff Road is the house Greenwich 8 the compound question. 9 Land owned, correct? And Ho Wan Kwok is the name of 9 MR. LUFT: Okay. 10 your husband, correct? 10 Ms. Interpreter, can you please explain 11 MR. LUFT: She just answered something, 11 what happened? 12 echo. You got to translate it. 12 (The reporter requested clarification.) 13 MR. MAJOR: Hold on. I have -- it's a 13 INTERPRETER: Can -- the interpreter was 14 compound question. You asked her what the 14 still interpreting the first question and 15 document was -- 15 Ms. -- Ms. Guo actually answered the second 16 MR. LUFT: She answered and it wasn't 16 question while I was interpreting them. 17 translated, Chris. 17 Can the interpreter reinterpret both the 18 MR. MAJOR: No, but you asked two 18 questions? 19 questions at once. 19 MR. LUFT: Why don't I just withdraw it 20 MR. LUFT: No, Chris, it just wasn't 20 and we'll just do it very quick? 21 translated. She answered. 21 INTERPRETER: Okay, then. 22 MR. MAJOR: I'm looking at the realtime, 22 BY MR. LUFT: 23 and I heard you -- 23 Q Exhibit 59 says 33 Ferncliff Road, which 24 MR. LUFT: Whatever the -- 'cause Echo 24 is a house you had previously told me was owned by 25 didn't translate it, Chris. 25 Greenwich Land, the name on the account of -- is Ho Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 49 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 50 of 52

1 Wan Kwok. That is your husband, correct? 1 BY MR. LUFT: 2 MR. MAJOR: Objection to form, including 3 compound.

5 33 Ferncliff Road house is under my husband's 6 name. 7 BY MR. LUFT: 7 BY MR. LUFT: 8 Q No, I understand that. The document -- 9 but Exhibit 59, which is the fuel agreement, states 10 that 33 Ferncliff Road is under your husband's name, 11 correct? 12 MR. MAJOR: Objection to form. 13 THE WITNESS: I still do not know what 14 this document means, even right now. 15 BY MR. LUFT: 16 Q Ms. Ngok, do you have any involvement with

17 paying the fuel bill for -- did you have any 17 MR. LUFT: Ms. Ngok, I have no further 18 involvement with paying the fuel bill for 18 questions at this time. Thank you very much 19 33 Ferncliff Road? 19 for what has been long and a very hot day in 20 A You mean fuel? What is it? 20 this room. 21 Q Yes. 21 THE WITNESS: Thank you, everybody. It 22 A It's like gasoline? 22 has been a hard day for everyone. Thank you so 23 Q The fuel that heats the home. 23 much. 24 A And then? Then what? 24 MR. MAJOR: Actually, I just want to put 25 Q My question is did you have any 25 two -- I'll be very, very quick. I'd like to

1 involvement in paying for the fuel bill for 1 mark the video and then the still images 2 33 Ferncliff Road? 2 thereof highly confidential for security 3 A I don't remember. 3 reasons. 4 Q Let me show you another document. 4 I'd like to reserve the right, as 5 MR. LUFT: We're going to mark as 5 ridiculous as it may sound, to read and sign. 6 Exhibit 60 a copy of a Petro Home Services bill 6 I just don't want to let that go. I know it's 7 to Ho Wan Kwok at 33 Ferncliff Road, Cos Cob, 7 a logistical situation and we may well not do 8 Connecticut. 8 that, but I just want to reserve that right. 9 (Exhibit 60 was marked for I.D.) 9 MR. LUFT: Okay. 10 BY MR. LUFT: 10 COURT REPORTER: And can I just get the 11 Q Ms. Ngok, do you see that this a copy of a 11 orders on the record? 12 fuel bill for 33 Ferncliff Road in the name of your 12 MR. LUFT: Sure. We'd like the rough and 13 husband, Ho Wan Kwok? 13 expedited. 14 MR. MAJOR: Objection to form. 14 MR. MAJOR: And I just ask that the 15 THE WITNESS: I see his name, yes, but I 15 transcript be marked "Confidential" except 16 don't recognize any other information on this 16 where we marked it "Highly confidential," and 17 page. 17 then we'll give it a review. And if there are 18 MR. LUFT: Let's go off the record for a 18 spots that don't need to be marked, we'll deal 19 minute. 19 with that then. 20 VIDEOGRAPHER: We're off the record. The 20 MR. LUFT: I will -- I don't agree that 21 time is 8:53. 21 everything on the record should be 22 (A recess was taken.) 22 confidential. And that's going to create a 23 VIDEOGRAPHER: We're back on the record. 23 major headache for the court when they have to 24 The time is 9:01. 24 use this, including the fact that we all have 25 25 to make any use of it and any filings, both in

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1 court and in briefs, confidential. I don't 1 C E R T I F I C A T E 2 think there's any basis, other than where we 2 I hereby certify that I am a Notary Public, 3 have specified that things should be marked 3 in and for the State of Connecticut, duly 4 "Confidential" or "Highly confidentially," to 4 commissioned and qualified to administer oaths. 5 say that the rest of the record needs to be 5 I further certify that the deponent named in 6 marked "Confidential" for the entire 6 the foregoing deposition was by me duly sworn, and 7 deposition. 7 thereupon testified as appears in the foregoing 8 MR. MAJOR: I was just saying it for a 8 deposition; that said deposition was taken by me 9 period of time, to allow us to review the 9 stenographically in the presence of counsel and 10 reduced to typewriting under my direction, and the 10 transcript to see if there's anything we want 11 foregoing is a true and accurate transcript of the 11 to mark "Confidential." We can deal with that 12 testimony. 12 off the record. 13 I further certify that I am neither of 13 And then, in terms of the order, I'll take 14 counsel nor attorney to either of the parties to 14 a -- I think regular delivery will be fine. 15 said suit, nor am I an employee of either party to 15 And I'm sure it includes it, but a mini as 16 said suit, nor of either counsel in said suit, nor 16 well. 17 am I interested in the outcome of said cause. 17 COURT REPORTER: And did you want a rough? 18 Witness my hand and seal as Notary Public 18 Sorry. 19 this 13th day of September, 2023. 19 MR. MAJOR: I don't think we need a rough, 20 20 but if we do, we'll reach out to you. Is that 21 _______________________________

22 COURT REPORTER: Sure. 22 Notary Public

24 MR. LUFT: Thank you, everyone. 24 My commission expires:

1 VIDEOGRAPHER: This is concludes today's 1 2 deposition. We're off the record at 9:05 p.m. 2 INDEX OF EXAMINATIONS 3 (The deposition concluded at 9:05 p.m.) 3

TRUSTEE'S EXHIBITS MARKED FOR I.D.

7 9 Exhibit 2 - Notice of Deposition, Greenwich

9 Exhibit 3 - Greenwich Land's Supplemental

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TRUSTEE'S EXHIBITS MARKED FOR I.D.

TRUSTEE'S EXHIBITS MARKED FOR I.D.

19 Exhibit 45 - "Minute Book of Gypsy Mei Food

Exhibit 46 - TRO and Preliminary Injunction,

TRUSTEE'S EXHIBITS MARKED FOR I.D.

TRUSTEE'S EXHIBITS MARKED FOR I.D.

Exhibit 57 - Residential Lease Renewal Waiver

21 Exhibit 59 - Retail Fuel Delivery and Service

Exhibit 33 - Exhibit 60 - Petro Home Services Bill, 33

(Reporter's note: Exhibits attached to original.)