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

METADATA

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

FULL TEXT

#### **Exhibit 53**

# **EXHIBIT B**

# **Exhibit 21**

## 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

![](_page_3_Picture_2.jpeg)

September 11, 2023

800.211.DEPO (3376) EsquireSolutions.com

YVer1f

HING CHI NGOK· Highly Confidential

| | Page 5 | | Page 7 | |----------|-------------------------------------------------------------------------------------|--------|--------------------------------------------------------------------| | 1 | VIDEOGRAPHER: This is Tape No. 1 to the | 1 2 | ECHO LIM, having first been duly 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: | | 4 5 | Land, et al., being heard before the United States Bankruptcy Court, District of | 5 | | | 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 | | | | | | | | | | | | | Page 6 | | Page 8 | | 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: Well, I'd like to, just for -- | 6 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 | | 17 18 | MR. LUFT: And -- COURT REPORTER: Please raise your | 18 | of deposition for Greenwich Land, LLC. Have you | | | | 19 | ever seen this document before? | | 19 20 | right -- 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 |

![](_page_4_Picture_2.jpeg)

| | Page 9 | | Page 11 | |----|------------------------------------------------------|----|------------------------------------------------------| | 1 | whether she has seen this document before. | | | | 2 | (Interpreter speaking Mandarin.) | | | | 3 | MR. MAJOR: Objection to form. | | | | 4 | THE WITNESS: I don't understand this | | | | 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? | | | | | | | 1 | Page 10 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. | | | | 25 | Ms. Ngok, as we've discussed, you're | | | | | | | | | | |

| | Page 13 | | Page 15 | |----|---------------------------------------------------------|----|-------------------------------------------------------| | 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? | | | | | | | 1 | Page 14 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 | | | | | |

![](_page_6_Picture_2.jpeg)

September 11, 2023

800.211.DEPO (3376) EsquireSolutions.com

YVer1f

HING CHI NGOK· Highly Confidential

| 1 | Page 17 them. I can't recall. I can't tell the content of | 1 | Page 19 MR. MAJOR: Objection to form. Instruct | |----------|-------------------------------------------------------------------------------------------------|----------|---------------------------------------------------------------------------------------| | 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 | | 23 24 | documents that we haven't received yet, if you just let us know and produce them, okay? | 23 24 | privileged. MR. MAJOR: To the extent it -- the | | 25 | MR. MAJOR: Yes. And I do not think there | 25 | question necessarily calls for discussions with | | | | | | | | | | | | | Page 18 | | Page 20 | | 1 | are documents that we have that you don't have | 1 | counsel. | | 2 3 | yet, but I will certainly triple-check that during a break. | 2 3 | MR. LUFT: No, it just calls for the name, the name of the person. She is here as | | 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? | | 22 | A I don't remember. | 22 23 | MR. MAJOR: Objection to form. Instruct the witness not to answer on the grounds of | | 23 24 | Q Who made the decision at Greenwich Land to change counsel from Updike Kelly to Mr. Major's | 24 | privilege. | | 25 | firm? | 25 | |

![](_page_7_Picture_2.jpeg)

| | Page 21 | | Page 23 | |----|------------------------------------------------------|----|------------------------------------------------------| | 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 | | 11 | (Exhibit 3 was marked for I.D.) | | | | | | 11 | Interrogatory No. 1 -- | | 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 | | | | | | | | | | | | | Page 22 | | Page 24 | | 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 | | |

![](_page_8_Picture_2.jpeg)

#### 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

![](_page_9_Figure_1.jpeg)

![](_page_9_Picture_2.jpeg)

# 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

September 11, 2023

800.211.DEPO (3376) EsquireSolutions.com

YVer1f

HING CHI NGOK· Highly Confidential

| 1 | Page 29 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 | | | | | | | | Page 30 | | Page 32 | | 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? | | 15 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? |

![](_page_10_Picture_2.jpeg)

# 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

![](_page_12_Figure_1.jpeg)

## 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

| Page 41 | Page 43 | |-------------------------------------------------------------------------------|--------------------------------------| | | 1 BY MR. LUFT: | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 14 BY MR. LUFT: | | | | | 16 BY MR. LUFT: | | | 17 Q Ms. Ngok, what address does Greenwich Land | | | 18 use for its banking? | | | 19 MR. MAJOR: Objection to form. | | | 20 THE WITNESS: I do not know. | | | 21 BY MR. LUFT: | | | | | | | | | | | | | | | Page 42 | Page 44 | | 1 INTERPRETER: She's asking a question. | 1 THE WITNESS: I do not remember. | | 2 THE WITNESS: I am unable to tell. | 2 BY MR. LUFT: | | 3 BY MR. LUFT: | | | 4 Q Ms. Ngok, what is the name of the company 5 that owns your home? | | | 6 A Let me think about it. | | | 7 Okay. I -- I struggle with spelling out | | | 8 the name of the company, so I used to use some | | | 9 Chinese similar pronunciation to write in Chinese | | | 10 character. It's called Guan Lei Chi. | | | 11 INTERPRETER: G-U-A-N L-E-I C-H-I. | | | 12 BY MR. LUFT: | | | 13 Q Is that in pinyin? Is that in pinyin? | | | 14 A Yes, it is pinyin. | | | 15 INTERPRETER: Ms. Guo -- Ms. Guo recorded | | | 16 it down in Chinese character; the interpreter | | | 17 made into pinyin. | | | 18 MR. LUFT: Okay. | | | 19 THE WITNESS: (In English) Sorry. | | | 20 BY MR. LUFT: | | | | | | | | | | | | | | | | | | | |

![](_page_13_Picture_2.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 14 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 15 of 52

| |-----------------------------------------------| | | 1 | | | | | | | | | | | | | | | | | | | | | | | | | | | 15 BY MR. LUFT: | 16 Q | | | 18 MR. MAJOR: Objection to form. | 19 THE WITNESS: I do not know. | 20 MR. LUFT: Let's mark as Exhibit 8 a | 21 document bearing the Bates Stamp | 22 | 23 (Exhibit 8 was marked for I.D.) | 24 INTERPRETER: Thank you. | 25 MR. LUFT: Of course. | | | 1 BY MR. LUFT: | | | 2 Q And I'll represent to you that this is | | 3 anothe | | | | | | | | 8 A Okay. | | | | | | | | | | | | | | | | | | | | | | | 19 BY MR. LUFT: | 20 Q | | | | | | | | | | | | | | Page 45 Page 47 | -----------------------------------------------| | | 2 MR. MAJOR: There's no question. | | 3 BY MR. LUFT: | | | | | | | | | | | | | | | | | | | | | | | | | | | 22 MR. LUFT: Okay. Let's mark as Exh bit 9 | | 23 a document | | | | | | | Page 46 Page 48 1 | | | | 3 (Exhibit 9 was marked for I.D.) | | 4 BY MR. LUFT: | | | | | | | | | | | | | | | | | | | | | | | | 23 Q | | | | |

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 15 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 16 of 52

![](_page_15_Figure_1.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 16 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 17 of 52

| Page 53 | Page 55 | |-----------------------------------------------|-------------------------------------------------------| | 1 MR. LUFT: Let's mark as Exhibit 11 a | 1 MR. MAJOR: Objection to form. | | 2 document bearing the Bates stamp | 2 THE WITNESS: I can't tell. I can't read. | | | 3 BY MR. LUFT: | | | 4 Q | | | | | | | | | | | | 7 MR. MAJOR: Objection to form. | | | 8 THE WITNESS: I do not know why. | | 9 (Exhibit 11 was marked for I.D.) | 9 BY MR. LUFT: | | 10 BY MR. LUFT: | 10 Q | | 11 Q | | | | | | | | | | | | | | | | 15 MR. MAJOR: Objection to form. | | 16 MR. MAJOR: Objection to form. | 16 THE WITNESS: I do not know. | | 17 THE WITNESS: I don't know. I can't -- I | 17 BY MR. LUFT: | | 18 don't recognize this document. | 18 Q | | 19 BY MR. LUFT: | | | 20 Q | | | | 21 MR. MAJOR: Objection to form and assumes | | | 22 a fact not established. | | 23 A I don't remember. | 23 MR. LUFT: What fact is that? | | 24 Q | 24 MR. MAJOR: Multiple facts in your | | | | | | 25 question -- alleged facts in your question. | | Page 54 | Page 56 | | 1 | 1 | | | | | | | | | | | 5 MR. MAJOR: Objection to form. | | | 6 THE WITNESS: | 6 MR. LUFT: We just walked through all the | | 7 BY MR. LUFT: | 7 documents, Mr. Major, showing that transfer, | | 8 Q Okay. | | | | 8 right? What more foundation could we have? | | | 9 MR. MAJOR: You're questioning a witness | | | 10 using English language documents even though | | | 11 you know she only reads Mandarin and trying to | | | 12 ask questions off of these documents. So I | | | 13 objected to the question; I didn't instruct the | | 14 MR. MAJOR: Objection to form. | 14 witness not to answer. But it's an improper | | 15 THE WITNESS: I -- I can't read these | 15 question, so I object to it. | | 16 words. | 16 MR. LUFT: Mr. Major, these are the bank | | 17 BY MR. LUFT: | 17 records and the statements of your client. | | 18 Q | 18 That they happen to be in English and you put | | | | | | 19 up a witness that doesn't speak English is your | | | 20 choice, but I can only use the records of the | | | 21 company. | | | 22 MR. MAJOR: I don't think these are | | | 23 documents we produced to you, based on the | | | 24 Bates numbering. | | | 25 MR. LUFT: You're right, Mr. Major. Some | | | | | | | | | | | | |

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 17 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 18 of 52

![](_page_17_Figure_1.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 18 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 19 of 52

![](_page_18_Figure_1.jpeg)

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

| Page 65 1 | Page 67 | |-------------------------------------------------------|-----------------------------------------------------------------------------------------| | | 1 reason for the objection. The other reason is | | | 2 she is the only person left at Greenwich Land, | | | 3 so if she doesn't know, the answer is obvious. | | | 4 But I can't -- I mean, I guess if you want | | | 5 me to, I could try to go back if you're asking | | 6 MR. MAJOR: Objection to form. | 6 me the basis for all of my objections. | | 7 THE WITNESS: This one (indicating), | 7 MR. LUFT: No. | | 8 right? | 8 MR. MAJOR: I'd have to -- there have been | | 9 BY MR. LUFT: | 9 a lot of questions. | | 10 Q Yes, ma'am. The first line and then the | 10 MR. LUFT: I don't think objecting to | | 11 second line. | 11 questions because you think the answer is | | 12 A Yes, I see it. | 12 obvious is a basis for objecting to a | | | 13 question -- | | | 14 MR. MAJOR: But the main reason for the | | | 15 objections is it was a nonsensical question: | | | 16 You're asking a witness who didn't know a fact | | | 17 if she knew who knew that fact so -- | | | 18 MR. LUFT: Well, she's the corporate | | | 19 representative for the company; this is a house | | | 20 that the company alleges that it owns. I don't | | | 21 think there's anything crazy about asking them | | | 22 who would know what law firm -- who hired the | | | 23 law firm that represented them. | | | 24 So we'll move on. I understand -- I'm | | | 25 aware that you made an objection -- | | Page 66 | Page 68 | | | 1 MR. MAJOR: I wasn't instructing the 2 witness not to answer, and I try to be | | | 3 extremely judicious when I object so that I | | | 4 don't interfere with your transcript. And | | | 5 that's why I've been, as I said, very | | | 6 circumspect in my objections. | | | 7 MR. LUFT: Okay. | | | 8 MR. MAJOR: Or I should say "concise" in | | | 9 my objections. | | | 10 BY MR. LUFT: | | | 11 Q Ms. Ngok, what homes have you lived in | | | 12 since you've come to the United States? Meaning the | | | 13 addresses. | | 14 the witness answered the question that she did | 14 A When I first came to the United States, I | | 15 not know. We've given you interrogatory | 15 live in town. | | 16 responses explaining that Mrs. Guo is the only | 16 Q "In town" meaning Manhattan? | | 17 person left at Greenwich Land, and then your | 17 A Correct. | | 18 next question was who at Greenwich Land would | 18 Q At the Sherry Netherland hotel? | | 19 know what the law firm was? | 19 INTERPRETER: Sheraton? | | 20 And I objected to that question on a | 20 MR. LUFT: Sherry Netherland. | | 21 number of grounds, including you're asking a | 21 THE WITNESS: Correct. | | 22 witness who doesn't -- who just said she | 22 BY MR. LUFT: | | 23 doesn't know a fact if she knows who knows that | | | 24 fact that she doesn't know. So the question | | | 25 doesn't make a lot of sense to me. That's one | | | | |

![](_page_19_Picture_2.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 20 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 21 of 52

![](_page_20_Figure_1.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 21 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 22 of 52

![](_page_21_Figure_1.jpeg)

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

![](_page_22_Figure_1.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 23 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 24 of 52

| Page 81 | Page 83 | |------------------------------------------------|--------------------------------------------------------------------------------------| | | 1 Q | | | | | | | | | 4 MR. MAJOR: Objection to form. | | | 5 THE WITNESS: I do not know why. | | | 6 BY MR. LUFT: | | | 7 Q | | | | | | | | | 10 MR. MAJOR: Objection to form. | | | 11 THE WITNESS: I do not know. | | | 12 BY MR. LUFT: | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 21 MR. LUFT: And I will mark as Exhibit 14 a | | | 22 copy of a document Bates | | | | | | | | | | | | | | | | | Page 82 | Page 84 | | | 1 | | | | | | 3 (Exhibit 14 was marked for I.D.) | | | 4 BY MR. LUFT: | | | 5 Q | | | | | | | | | 8 MR. MAJOR: Objection to form. | | | 9 THE WITNESS: | | | 10 Okay. | | 11 BY MR. LUFT: | 11 BY MR. LUFT: | | 12 Q | 12 Q And if I ask you to turn to page ending in | | | 13 Bates number 42 -- | | | 14 MR. MAJOR: I don't think she'll know what | | | 15 a Bates number is. I can flip it for her or -- | | | 16 okay. | | 17 MR. MAJOR: Objection to form. | 17 INTERPRETER: I can help her. | | 18 THE WITNESS: This one (indicating), | 18 MR. MAJOR: Okay, please. | | 19 right? | 19 THE WITNESS: I'm on it. | | 20 BY MR. LUFT: | 20 BY MR. LUFT: | | 21 Q Yes, ma'am, the third one. | 21 Q | | 22 A No, it's this (indicating) -- | | | 23 Q Oh, sorry. Yes, correct, ma'am. You're | 23 MR. MAJOR: Objection to form. The | | 24 right. | | | 25 A Okay. I see it. | 24 witness can't read the words. 25 THE WITNESS: I'm not -- I can't read. I |

![](_page_23_Picture_2.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 24 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 25 of 52

| 1 | Page 85 really can't read. | 1 if Greenwich Land holds any ownership interest in | Page 87 | |----|-------------------------------------------------|--------------------------------------------------------|---------| | 2 | MR. LUFT: I understand. Not a problem. | 2 Saraca Media. | | | 3 | BY MR. LUFT: | 3 A I do not know. | | | | | 4 Q | | | | | | | | | | | | | | | | | | | | 8 MR. MAJOR: Objection to form. | | | | | 9 THE WITNESS: I am not sure about that. | | | | | 10 BY MR. LUFT: | | | | | 11 Q | | | | | | | | | | | | | | | | | | | | | | | | | 16 A I do not know. | | | | | 17 Q | | | | | | | | 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? | | | | 25 | A What do you mean by that? | 25 MR. MAJOR: Objection to form. | | | | Page 86 | | Page 88 | | 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. | | | | 15 | MR. MAJOR: If she's not well, she | | | | 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 | | | | 20 | record. | 20 (Exhibit 15 was marked for I.D.) | | | 21 | (A recess was taken.) | 21 MR. LUFT: And would it be okay for us to | | | 22 | VIDEOGRAPHER: We're back on the record. | 22 just email a copy of it? | | | 23 | The time is 3:50. | 23 COURT REPORTER: Sure. | | | 24 | BY MR. LUFT: | 24 MR. LUFT: All right. So that's what | | | | Q Ms. Ngok, before we broke, I had asked you | 25 we'll do. | | | 25 | | | |

![](_page_24_Picture_2.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 25 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 26 of 52

| | Page 89 | | | | Page 91 | |----|----------------------------------------------------|----|---|-----------------------------------------|---------| | 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. | | | 14 | that that | 14 | Q | | | | | | | | | | | | | | | | | | 17 | A I don't remember clearly. | 17 | | | | | 18 | Q | | | | | | | | | | | | | | | | | | | | | off the record.) | | | | | | | | | | | | | 22 | THE WITNESS: I don't remember. | 22 | | BY MR. LUFT: | | | 23 | MR. LUFT: Okay. Let's mark as | 23 | | Q That's okay. | | | 24 | Exhibit 16, | 24 | | | | | | | | | | | | | Page 90 | | | | Page 92 | | 1 | | 1 | | | | | | | 2 | | A I don't remember. | | | | | 3 | Q | | | | | | | | | | | | | | | | | | | | 6 | | A I have gone to view the house before. | | | | | | | | | | | were marked for I.D.) | 7 | | Q I appreciate -- that's helpful. | | | 8 | BY MR. LUFT: | 8 | | | | | 9 | Q Ms. Ngok, my first question is simple: | | | | | | 10 | | | | | | | | | | | | | | | | | | | | | 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: | | | | | | 19 | Q | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 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

| | Page 93 | | Page 95 | | |-----------|------------------------------------------------------|----|-------------------------------------------|--| | 1 | Q | 1 | | | | | | 2 | BY MR. LUFT: | | | | | 3 | Q Okay. And do you see -- | | | 4 | A I don't. | 4 | A | | | 5 | Q | 5 | Q Understood. | | | | | 6 | | | | | | | | | | | | | | | | 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. | | | | | | Page 94 | | Page 96 | | | 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: | | | | | 7 | Q | | | | | | | | | | | | | | | | | | | | | | | | | | | 12 | A Can you point it out to me which page it | | | | | 13 is? | | | | | | 14 | Q Of course, ma'am. I can show you on mine. | | | | | 15 | I'm about eight pages in -- | | | | | | | | | | | 16 | MR. LUFT: | | | | | | | | | | | 18 | THE WITNESS: You mean this page | | | | | 19 | (indicating)? | | | | | 20 | BY MR. LUFT: | | | | | 21 | Q | | | | | | | 22 | INTERPRETER: Sorry. | | | | | 23 | BY MR. LUFT: | | | 24 | MR. MAJOR: Objection to form. | 24 | Q | | | 25 | THE WITNESS: , | | | | | | | | | |

![](_page_26_Picture_2.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 27 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 28 of 52

| Page 97 1 3 A I don't remember. 4 Q Okay. You can put that aside. 5 A Okay. 6 Q Let me show you, then -- 7 MR. LUFT: Let's mark as Exhibit 20 -- 8 (A discussion was held off the 9 stenographic record.) 10 MR. LUFT: We'll mark as Exhibit 20 a 11 document with the control number CTRL00016119. 12 Again, this is a multipage document that was 13 produced to us without Bates stamps, so we just 14 put it on there. 15 | Page 99 1 THE WITNESS: No, it's not. 2 MR. LUFT: It's -- I don't want to say it, 3 'cause I assume you don't want her social 4 security number in the record so 5 MR. MAJOR: 7 MR. LUFT: Well 8 BY MR. LUFT: 9 Q 12 A You mean this one (indicating)? 13 Q Yes, ma'am. 14 A | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | 19 (Exhibit 20 was marked for I.D.) 20 THE WITNESS: Okay. 21 BY MR. LUFT: 22 Q Page 98 1 of you. 2 A Where did you see page No. 7? 3 Q | 23 MR. LUFT: Completely fair. 24 THE WITNESS: I do not -- I don't speak 25 English, I don't understand English, and I Page 100 1 2 BY MR. LUFT: 3 Q | | 7 MR. MAJOR: Can I just flip to it for her? 8 MR. LUFT: I -- I did. She has it. 9 THE WITNESS: I am on it, but I don't know 10 if that's the correct one. 11 BY MR. LUFT: 12 Q That's the correct -- you're on the same 13 page as me. 14 19 A | don't remember. I really don't 11 remember. 12 Q Okay. | | 24 THE WITNESS: No, it is not either. 25 MR. LUFT: No, it's not -- it's | 25 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

| Page 101 Page 103 1 | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | 3 MR. MAJOR: Objection to form. 4 THE WITNESS: Okay. I see it. 5 BY MR. LUFT: 6 Q | | 9 MR. MAJOR: Objection to form. 10 THE WITNESS: Yes. 11 BY MR. LUFT: 12 Q | | 19 MR. MAJOR: Objection to form. 20 THE WITNESS: I do not know. 21 BY MR. LUFT: 22 Q | | Page 102 Page 104 1 MR. MAJOR: Objection. 2 THE WITNESS: I don't know. 3 BY MR. LUFT: reporter to mark as Exhibit 21 another document | | 12 BY MR. LUFT: 13 Q Does anyone at Greenwich Land know the | | 14 answer to that question? 15 MR. MAJOR: Objection to form. 16 THE WITNESS: Can you repeat? 17 MR. LUFT: Sure. 18 BY MR. LUFT: | | 19 Q Does anyone at Greenwich Land know the 20 answer to that question? 21 MR. MAJOR: Objection to form. 22 THE WITNESS: Me too don't know. 23 MR. LUFT: Okay. Ms. Ngok, I want to 24 be -- it's warm in here. How are you feeling? 25 And do you need a break? | | |

![](_page_28_Picture_2.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 29 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 30 of 52

![](_page_29_Figure_1.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 30 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 31 of 52

![](_page_30_Figure_1.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 31 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 32 of 52

| | Page 113 | Page 115 | |----|----------------------------------------------------|-----------------------------------------------------------| | 1 | Ms. Ngok, do you know what Bento | 1 THE WITNESS: I don't remember. | | 2 | Technologies is? | 2 BY MR. LUFT: | | 3 | A I do not know. | 3 Q | | 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. | | 11 | Technologies, correct? | 11 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. | | | 16 | (Ms. Song speaking Mandarin.) | | | 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 | | 21 | consumptions. So the part of -- | 21 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. | | | 24 | INTERPRETER: Can the interpreter | | | 25 | reinterpret? | | | | Page 114 | Page 116 | | 1 | MR. LUFT: That's perfectly fine. | | | 2 | INTERPRETER: Yeah, that's the proper way | | | 3 | to do it. | | | 4 | (Interpreter speaking Mandarin.) | | | 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. | | | | | | | | | |

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 32 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 33 of 52

![](_page_32_Figure_1.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 33 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 34 of 52

| Page 121 | Page 123 | |----------------------------------------------------------|----------------------------------------------------------| | 1 the record; you don't have to do anything with them | 1 | | 2 right now. | | | 3 MR. LUFT: I marked a document bearing -- | | | 4 as Exhibit 34 bearing the Bates stamp | | | 5 | 5 Chris, do you want her to translate all | | | 6 that or? | | | 7 MR. MAJOR: I'm okay not translating all | | | 8 that. | | 9 As Exhibit 35, the next in that series, | 9 MR. LUFT: Okay. | | 10 | 10 THE WITNESS: Okay. I'll just give a gist | | | 11 of it. | | | 12 MR. LUFT: You can just tell her that I -- | | | 13 INTERPRETER: Oh, sorry. Just give me one | | 14 (A discussion was held off the | 14 second. | | 15 stenographic record.) | 15 (Interpreter speaking Mandarin.) | | 16 MR. LUFT: Exh bit -- we've marked as | 16 THE WITNESS: Okay. | | 17 Exhibit 36 another | 17 BY MR. LUFT: | | | 18 Q Ms. Ngok, I'll ask you to turn to -- if | | | 19 you could just pull out Exhibit 22 and Exhibit 33. | | | 20 | | | | | 22 We marked as Exhibit 37 a | | | | 23 INTERPRETER: Sorry. | | | 24 MR. LUFT: Go ahead. | | | 25 THE WITNESS: Yes. | | | | | Page 122 | Page 124 | | 1 Exhibit -- we marked as Exhibit 38 | 1 BY MR. LUFT: | | | 2 Q | | | | | | | | | | | 6 We marked as Exhibit 39 | | | | 7 MR. MAJOR: Objection to form. | | | 8 THE WITNESS: I see it. | | | 9 BY MR. LUFT: | | | 10 Q | | 11 We marked as Exhibit 40 | | | | | | | | | | | | | | | 16 And we marked as Exhibit 41 | 16 MR. MAJOR: Objection to form. | | | 17 THE WITNESS: Which date? | | | 18 MR. LUFT: | | | 19 THE WITNESS: Yes, I see it. | | 20 We marked as Exhibit 42 | 20 BY MR. LUFT: | | | 21 Q Okay. In the interest of trying to save | | | 22 time | | | | | | | | 25 And as Exhibit 43, | | | | | | | |

Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 34 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 35 of 52

| Page 125 | Page 127 | |----------------------------------------------------------|-----------------------------------------------------------| | 1 | 1 BY MR. LUFT: | | | 2 Q Ms. Ngok, who had the authority to write | | | 3 checks on behalf of Greenwich Land's bank account at | | | 4 The First Bank of Greenwich? | | | 5 MR. MAJOR: Objection to form. | | 6 INTERPRETER: Thank you. | 6 THE WITNESS: I do not know. | | 7 MR. LUFT: Thank you. | 7 BY MR. LUFT: | | 8 THE WITNESS: I understand. | 8 Q Who at -- who at Greenwich Land had to | | 9 BY MR. LUFT: | 9 authorize the writing of checks from Greenwich | | 10 Q | 10 Land's bank account at The First Bank of Greenwich? | | | 11 MR. MAJOR: Objection to form. | | | 12 THE WITNESS: I do not know. | | | 13 BY MR. LUFT: | | | 14 Q Ms. Ngok, are you familiar with a company | | | | | | 15 called Gypsy Mei -- M-E -- "Mei" is spelled M-E-I, | | 16 A Yes. | 16 same as your daughter's -- Food Service, LLC? | | 17 Q | 17 A I am not familiar with this. | | | 18 MR. LUFT: Okay. So let's mark as | | | 19 Exhibit 45 a document bearing the Bates stamp | | | 20 HR0003000 through 32, titled "Minute Book of | | | 21 Gypsy Mei Food Services, Hodgson Russ, | | | 22 Attorneys." | | | 23 (Exhibit 45 was marked for I.D.) | | | 24 BY MR. LUFT: | | 25 MR. MAJOR: Objection to form. | | | Page 126 | Page 128 | | 1 THE WITNESS: I do not know. | | | 2 BY MR. LUFT: | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 13 Q Okay. We're going to come back to these, | | | 14 but for now you can put them to the side for a | | | 15 second. | | | 16 (A discussion was held off the | | | 17 stenographic record.) | | | 18 BY MR. LUFT: | | | 19 Q Ms. Ngok, I'm going to ask the court | | | 20 reporter to mark as Exhibit 44 a document produced | | | 21 to us by | | | | | | The document bears the Bates stamp -- or | | | | | | 24 control number CTRL00016116. | 24 BY MR. LUFT: | | 25 (Exhibit 44 was marked for I.D.) | | | | |

![](_page_34_Picture_2.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 35 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 36 of 52

![](_page_35_Figure_1.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 36 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 37 of 52

![](_page_36_Figure_1.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 37 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 38 of 52

![](_page_37_Figure_1.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 38 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 39 of 52

![](_page_38_Figure_1.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 39 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 40 of 52

| | Page 145 | | Page 147 | |----|------------------------------------------------------|----|------------------------------------------------------| | 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. | | | | | | | 1 | Page 146 MR. MAJOR: Objection to form. | 1 | Page 148 (A discussion was held off the | | 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: | | | | 13 | Q Okay. Well, when you signed the | | | | 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 | | | | | |

![](_page_39_Picture_2.jpeg)

Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 40 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 41 of 52

![](_page_40_Figure_1.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 41 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 42 of 52

| Page 153 | Page 155 | |-------------------------------------------------|-------------------------------------------------------------| | 1 | | | | | | | | | 4 (Exhibit 47 was marked for I.D.) | | | 5 MR. LUFT: I'm going to ask the court | | | 6 reporter to mark as Exhibit 48 | 6 MR. MAJOR: Objection to form. | | | 7 THE WITNESS: | | | | | | | | 10 (Exhibit 48 was marked for I.D.) | | | 11 MR. LUFT: I'm going to ask the court | | | 12 reporter to mark as Exhibit 49 | 12 BY MR. LUFT: | | | 13 | | | | | | | | 16 (Exhibit 49 was marked for I.D.) | 16 MR. MAJOR: Objection to form. | | 17 MR. LUFT: And I'll ask the court reporter | 17 THE WITNESS: | | 18 to mark Exhibit 50 | | | | | | | 21 BY MR. LUFT: | | 22 (Exhibit 50 was marked for I.D.) | 22 Q Okay. Well, Ms. Ngok, let's just go to | | 23 MR. LUFT: | 23 our most recent one, which is from -- well, let me | | | 24 strike that. Let me find one that may stick out a | | | 25 bit more. | | | | | Page 154 1 | Page 156 1 And -- well, let me first -- let me strike | | | 2 that. | | | 3 (The following testimony was deemed highly | | | 4 confidential.) | | | 5 BY MR. LUFT: | | 6 MR. MAJOR: Objection to form. | 6 Q | | 7 THE WITNESS: I'm not able to read this | | | 8 document. | | | 9 BY MR. LUFT: | | | 10 Q | 10 (The reporter requested clarification.) | | | 11 BY MR. LUFT: | | | | | | | | 14 INTERPRETER: Can I have the question | | | 15 again, sir? | | | 16 MR. LUFT: You could just strike it. | | | 17 BY MR. LUFT: | | | 18 Q | | | | 19 MR. MAJOR: Hold on. Hold on. I don't | | | 20 want to have any attorney-client privileged | | 21 A Yes. | 21 communications put on the record. So I just | | 22 Q | 22 want to -- I don't know what the best thing to | | | 23 do is, but I'd like to maybe -- and I have no | | | 24 idea what the rest of the answer was, so I | | | 25 don't know if it just a passing reference or | | | |

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 42 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 43 of 52

![](_page_42_Figure_1.jpeg)

![](_page_42_Picture_2.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 43 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 44 of 52

| | Page 161 | Page 163 | |---------------------------------|----------|---------------------------------------------------| | BY MR. LUFT: | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 24 | BY MR. LUFT: | | | 25 | Q Ms. Ngok, are you familiar with the | | | | | | | Page 162 | Page 164 | | 1 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. | | | | | | | | | | | | | | | | | | | | | | | | |

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 44 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 45 of 52

| Page 165 | Page 167 | |---------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------| | 1 THE WITNESS: I only have breakfast in the 2 restaurant when I first came to the United | | | 3 States back in 2017. | | | | | | | | | 6 BY MR. LUFT: 7 Q But he is a person who has signed -- | | | 8 opened bank accounts and signed documents on behalf | | | 9 of Greenwich Land, correct? | | | 10 MR. MAJOR: Just objection to form. | | | 11 I'm sorry. 12 THE WITNESS: I don't know about that. | | | 13 BY MR. LUFT: | | | | | | | | | | | | | | | | | | | | | | 21 (Exhibit 51 was marked for I.D.) 22 BY MR. LUFT: | | | 23 Q | | | | | | | | Page 166 | Page 168 | | | 1 A I don't remember. 2 Q Okay. Let me show you -- let's mark as | | | 3 Exhibit 52 a | | | | | | | | | 7 (Exhibit 52 was marked for I.D.) | | | 8 BY MR. LUFT: | | | 9 Q | | | | | | form. 12 THE WITNESS: | | | | | | 14 BY MR. LUFT: | | | 15 Q | | | | | | | | | | | | | | | 21 MR. MAJOR: Objection to form. 22 THE WITNESS: I don't remember. | | | 23 MR. LUFT: Okay. Let's mark as -- | | | 24 MR. MAJOR: Can I just ask a question on | | | 25 Exhibit 52? | | | |

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 45 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 46 of 52

![](_page_45_Picture_1.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 46 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 47 of 52

| Page 173 | Page 175 | |------------------------------------------------|----------------------------------------------------------------------------------------------------------------------| | 1 BY MR. LUFT: | 1 later? | | 2 Q What if -- please tell me -- | 2 MR. MAJOR: Objection to form. | | 3 A I do not know who. | 3 THE WITNESS: I do not know. | | 4 INTERPRETER: Sorry. | 4 BY MR. LUFT: | | 5 MR. LUFT: Okay. | 5 Q | | 6 BY MR. LUFT: | | | | | | | 8 A I do not know. | | | 9 Q Ms. Ngok, are you familiar with someone by | | 10 MR. LUFT: Okay. Let's mark as Exhibit 55 | 10 the name of Dinggang Wang? | | 11 a | 11 INTERPRETER: Can I have the spelling of 12 the name, sir? | | | 13 MR. LUFT: D-I-N-G-G-A-N-G, space, Wang, | | 14 (Exhibit 55 was marked for I.D.) | 14 W-A-N-G. | | 15 BY MR. LUFT: | 15 THE WITNESS: I am not familiar. | | | 16 BY MR. LUFT: | | | 17 Q | | | | | | 19 A I do not know. | | | 20 Q Okay. Ms. Ngok, I'm going to have marked | | | 21 as Exhibit -- what are we up to, 56? -- 56 documents | | | 22 entitled "Residential Lease Renewal Agreement," | | | 23 between Greenwich Land, LLC, and Wang Dinggang. | | | 24 (Exhibit 56 was marked for I.D.) | | 25 A I don't know. I don't know why. | 25 | | Page 174 | Page 176 | | 1 (A discussion was held off the record.) | 1 BY MR. LUFT: | | 2 BY MR. LUFT: 3 Q | 2 Q Ms. Ngok, do you recognize this document? 3 A I don't remember. | | | 4 Q Did you ever authorize Greenwich Land to | | | 5 lease 33 Ferncliff to a man named Dinggang Wang? | | | 6 A I don't remember. | | | 7 Q Ms. Ngok, I'm going have the court | | | 8 reporter mark as Exhibit 57 a copy of a document | | | 9 entitled "Residential Lease Renewal Waiver | | 10 MR. MAJOR: Objection to form. | 10 Agreement," which is an agreement between, again, | | 11 THE WITNESS: I really do not know why. | 11 Greenwich Land, LLC, and Mr. Wang Dinggang dated | | 12 BY MR. LUFT: | 12 October 9, 2020. | | 13 Q | 13 (Exhibit 57 was marked for I.D.) | | | 14 BY MR. LUFT: | | | 15 Q Ms. Ngok, who authorized Greenwich Land to | | | 16 enter into this agreement with Mr. Dinggang Wang 17 related to he and his family living at 33 Ferncliff? | | 18 MR. MAJOR: Objection. | 18 MR. MAJOR: Objection to form. | | 19 THE WITNESS: I do not understand your | 19 THE WITNESS: I'm not sure. | | 20 question. | 20 BY MR. LUFT: | | 21 BY MR. LUFT: | 21 Q Okay. Ms. Ngok, is part of Greenwich | | 22 Q | 22 Land's business to do media consulting? | | | 23 A I'm not sure. | | | 24 Q You're the sole member of Greenwich Land. | | | 25 Are you aware of any media business that Greenwich | | | |

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 47 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 48 of 52

![](_page_47_Figure_1.jpeg)

# Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 48 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 49 of 52

| | Page 181 | 1 | Page 183 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 | | 10 | stenographic record.) | 10 | then -- | | 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." | | | | | | | | | | | | | Page 182 | | Page 184 | | 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 |

![](_page_48_Picture_2.jpeg)

# 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

| | Page 185 | | Page 187 | |----|------------------------------------------------------|----|------------------------------------------------| | 1 | Wan Kwok. That is your husband, correct? | 1 | BY MR. LUFT: | | 2 | MR. MAJOR: Objection to form, including | | | | 3 | compound. | | | | 4 | THE WITNESS: I never said that the | | | | 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 | | | Page 186 | | Page 188 | | 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 | | | | | | | | | | |

![](_page_49_Picture_2.jpeg)

## Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 50 of 51 Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 51 of 52

| | Page 189 | | Page 191 | |----|-----------------------------------------------|--------|---------------------------------------------------------------| | 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 | _______________________________ | | 21 | okay? | | Deborah Gentile | | 22 | COURT REPORTER: Sure. | 22 | Notary Public | | 23 | THE WITNESS: Thank you. | 23 | | | 24 | MR. LUFT: Thank you, everyone. | 24 | My commission expires: October 31, 2026 | | 25 | MS. SONG: Thank you. | 25 | | | | Page 190 | | Page 192 | | 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 4 | PAGE DIRECT EXAMINATION BY MR. LUFT 7 | | 4 | | 5 | | | 5 | | 6 7 | INDEX OF EXHIBITS TRUSTEE'S EXHIBITS MARKED FOR I.D. | | 6 | | 8 | Exhibit 1 - Notice of Deposition, Ms. Ngok 7 | | 7 | | 9 | Exhibit 2 - Notice of Deposition, Greenwich 8 Land, LLC | | 8 | | 10 | | | 9 | | | Exhibit 3 - Greenwich Land's Supplemental 21 | | 10 | | 11 | Responses to Interrogatories, 9/9/23 | | 11 | | 12 | | | 12 | | | Exhibit 4 - | | 13 | | 14 | Exhibit 5 - | | 14 | | | | | 15 | | 15 | Exhibit 6 - | | 16 | | | | | 17 | | 17 | Exhibit 7 - | | 18 | | 18 | | | 19 | | | Exhibit 8 - | | 20 | | 20 | Exhibit 9 - | | | | | | | 21 | | 21 | Exhibit 10 - | | 22 | | | | | 23 | | 23 | Exhibit 11 - | | 24 | | 24 | | | 25 | | 25 | | | | | | |

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

| Page 193 | Page 195 | |----------------------------------------------|---------------------------------------------------------------------------------| | 1 2 INDEX OF EXHIBITS (CONT'D) | 1 2 INDEX OF EXHIBITS (CONT'D) | | 3 TRUSTEE'S EXHIBITS MARKED FOR I.D. 4 | 3 TRUSTEE'S EXHIBITS MARKED FOR I.D. 4 | | Exhibit 12 - | Exhibit 35 - | | 6 Exhibit 13 - | Exhibit 36 - 6 | | 7 Exhibit 14 - | 1 Exhibit 37 | | Exhibit 15 ਰੇ | Exhibit 38 ਰੇ | | 10 | 10 | | Exhibit 16 | Exhibit 39 | | Exhibit 17 - 12 | Exhibit 40 12 | | 13 | 13 Exhibit 41 - | | Exhibit 18 - | 15 Exhibit 42 | | 15 Exhibit 19 | 16 | | 16 Exhibit 20 | Exhibit 43 - | | Exhibit 21 - 18 | Exhibit 44 - 18 19 | | 19 | Exhibit 45 - "Minute Book of Gypsy Mei Food 127 20 Services " | | Exhibit 22 - | 21 Exhibit 46 - TRO and Preliminary Injunction, 152 3/28/23 | | 21 Exhibit 23 - | 22 Exhibit 47 - | | 22 23 | Exhibit 48 - 24 | | 24 25 | 25 | | Page 194 | Page 196 | | 1 2 INDEX OF EXHIBITS (CONT'D) | 1 2 INDEX OF EXHIBITS (CONT'D) | | 3 TRUSTEE'S EXHIBITS MARKED FOR I.D. 4 | 3 TRUSTEE'S EXHIBITS MARKED FOR I.D. 4 | | Exhibit 24 - | Exhibit 49 | | Exhibit 25 - 6 | Exhibit 50 6 | | 7 Exhibit 26 - 8 | 7 Exhibit 51 - | | | Exhibit 52 ರಿ | | 2 Exhibit 27 - 10 | 10 | | | Exhibit 53 - | | Exhibit 28 12 | 12 Exhibit 54 | | Exhibit 29 - । ব | 13 | | | Exhibit 55 - | | | 175 15 Exhibit 56 - Residential Lease Renewal Agreement, Mr. Wang | | Exhibit 31 18 | 16 Exhibit 57 - Residential Lease Renewal Waiver 176 | | | Agreement, Mr. Wang, 10/9/20 17 18 Exhibit 58 | | 20 Exhibit 32 - | 19 | | 21 | Exhibit 59 - Retail Fuel Delivery and Service 181 20 Agreement, 2/6/20 | | Exhibit 33 - | Exhibit 60 - Petro Home Services Bill, 33 21 186 Ferncliff Road | | 23 Exhibit 34 | 22 (Reporter's note: Exhibits attached to original.) 23 | | 24 25 | 24 25 | | A FOOTTIDE | |